United States v. Leke

Someone stole $40,000 from a branch bank's ATM cassettes overnight; only three employees, including Adam Leke (defendant), had access to the machine, and the physical evidence pointed to an inside job. Leke had stocked the ATM with the stolen amount the day before, visited it again the next day on a pretext, and behaved deceptively during questioning; a bank investigator found a co-worker credible in denying involvement, and Leke's cooperating accomplice, Ward, testified the two of them devised the scheme together and that Ward's cut left him with thousands of dollars in cash. Leke himself showed no comparable sudden wealth, and the jury convicted him based on this circumstantial evidence; he appealed, arguing the government needed physical evidence or proof of his own sudden wealth.