Copyright

People v. Pratt: Facts, Decision, & Significance

Instructor: Natalie Boyd

Natalie is a teacher and holds an MA in English Education and is in progress on her PhD in psychology.

What does the word 'stolen' mean? In the legal system, even a simple question like that can be difficult to answer. In this lesson, we'll examine the Michigan case 'People v. Pratt,' and how it grappled with that very question.

Stolen Property

''Can I steal your pen for a moment? ''

''You weren't around to ask, so I went ahead and borrowed your sweater. ''

We say things like this every day, making it clear that in common vernacular, the words 'steal' and 'borrow' are interchangeable. But what do they mean in the legal system? For the purposes of the law, what constitutes stealing and what constitutes borrowing?

These questions lie at the heart of the Michigan Supreme Court case The People of the State of Michigan v. Pratt, which is often simply referred to as People v. Pratt. Let's look closer at this 2002 case.

The Case

Eddie Pratt was caught driving his ex-girlfriend's car. While Pratt said that he borrowed the car from her, his ex-girlfriend said that he took the car without her permission. Based on his ex's testimony, Pratt was convicted of receiving and concealing stolen property. He appealed the conviction and eventually the case made its way to the Michigan Supreme Court.

Pratt's appeal rested on the legal definition of stolen property. He argued that the only way for something to be stolen would be through larceny, or theft of personal property. Legally speaking, larceny can only occur if the thief intends to permanently keep what they've stolen. That is, larceny occurs if the person taking property does not intend to give the property back.

But Pratt had always argued that he intended to return the car to his ex, so he hadn't committed larceny. But did this mean that the car wasn't stolen? Pratt's lawyers argued that's exactly what it meant. They argued that because the court had no evidence that Pratt intended to keep the car, and therefore hadn't committed larceny, his conviction of receiving stolen property should be overturned.

Decision

When the case got to the Michigan State Supreme Court, the court had to decide what stolen property was. At the heart of this case was the definition of the word 'stolen.' While larceny was clearly defined in legal terms, the word stolen was not. To decide the case, then, the court had to define 'stolen.'

Because there was no definition of the word 'stolen' in the state law, the court applied the dictionary definition of stolen. The dictionary defined stolen goods as property taken without permission, with no reference to whether the goods were intended to be returned or not.

So what happened with Pratt's appeal? Based on the legal definition, the court agreed with Pratt that there wasn't evidence he had committed larceny. But remember that larceny wasn't what he had been convicted of. The court found that his original conviction was correct, even in the absence of larceny, because he had taken the car without permission.

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