What is the basis for a finding of possession of stolen goods in the trunk of a car?

California, United States of America


The following excerpt is from People v. Banks, B258143 (Cal. App. 2015):

Appellant relies on cases which hold mere access or proximity to stolen goods without evidence from which dominion and control can be inferred is insufficient to support a finding of possession. (See e.g. People v. Martin (1973) 9 Cal.3d 687, 695-696 [evidence defendant had stolen goods in the trunk of his car, taken from codefendant's

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car, inadequate to sustain conviction for receiving the stolen property in codefendant's car]; People v. Myles (1975) 50 Cal.App.3d 423, 429 [evidence stolen television sets are found in trunk of car in which the defendant was a passenger insufficient to sustain conviction for receiving stolen property].)

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