California, United States of America
The following excerpt is from People v. Signorelli, F077270 (Cal. App. 2020):
In rejecting the reasoning in People v. Williams, the court explained that receiving stolen property is not a theft offense: it does not include the elements of "'taking with intent ... to permanently deprive the owner of its possession[]'" as does theft; "[b]ecause a 'theft conviction operates as a bar to a receiving conviction' [citation], it is difficult to understand how receiving stolen property could amount to theft[]"; and "interpreting receiving stolen property to be a form of a theft offense would render part of Proposition 47 superfluous." (Orozco, supra, 9 Cal.5th at pp. 121, 122.)
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