State v. Brown

While Minnie Montgomery was unloading a company van, Brown (defendant) offered to help, but she declined and kept working. Moments later she saw the van pulling toward the parking lot exit and recognized Brown as the driver before it disappeared. Officer Michael Moss, responding to a description of the van, went straight to an alley known for stashing stolen vehicles and found the van there with Brown still inside, trying unsuccessfully to escape through blocked doors. Brown was arrested about 15 minutes after the van was taken, with its keys in his possession, though nothing turned out to be missing from the vehicle, which the owner valued at $2,000. Brown was convicted of theft, which required intent to deprive the owner of property worth $1,000 to $10,000, and appealed, arguing the short time between the taking and his capture showed he lacked the intent to deprive.