United States v. Donato-Morales

Juan Donato-Morales (defendant) agreed with a store clerk to buy a cheaper Mitsubishi VCR model, then switched it for a pricier model in the cheaper model's box before paying only the lower price; both boxes looked alike and were unmarked with prices. Store security caught him, and he was prosecuted for larceny under a statute that did not itself list specific intent as an element, though the Supreme Court had held Congress implicitly retained that common-law requirement. At his bench trial, the clerk testified Donato-Morales said he intended to buy the cheaper model, surveillance footage showed him behaving furtively while switching the VCRs, and evidence showed he lied to investigators and gave signs of fabricating his own trial testimony; the judge found him guilty, and he appealed.