Public-domain · open source
OpenJurist

656 S.W.2d 727

Brown v. Commonwealth

Kentucky Supreme Court

Decided June 15, 1983

Kentucky Supreme Court · decided 1983-06-15

Applies KY 514 § 514.040

Relies on Jackson v. Virginia · In the Matter of Samuel Winship

Good law ✅— No negative treatment on recordhow we know

Decided 1983-06-15

How this case has been cited

Cited by 7 later decisions — most recently March 2013

2 federal appellate · 3 state decisions

501983199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

GANT, Justice,

¶1concurring.

¶2I, too, would affirm the conviction herein but do not feel that reliance should remain a necessary element. The standard for conviction in a criminal case was clearly defined in Jackson v. Virginia, 443 U.S. 307, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979), citing In re Winship, 397 U.S. 358, 90 S.Ct. 1068, 25 L.Ed.2d 368 (1970). That standard is that no person may be convicted except upon proof beyond a reasonable doubt of every element of the offense charged. In examining KRS 514.040(l)(a) to determine every element of the offense, we find that those elements are clearly enunciated as (1) obtaining property of another, (2) by deception, and (3) with intention to deprive him thereof. There is simply no statutory requisite of reliance on the false impression, merely that the perpetrator obtained the property by false impression, with intent to deprive. At that point the offense denounced by the statute is complete, and all requisite elements were proved in the instant case. It is the state of mind of the criminal, not the victim, which the statute denounces.

/656/sw2d/727 · .json · Public domain