Idaho v. Coats

Defendant Shawn Coats was charged with eight different offenses after he took an elderly man’s debit card and deposited fraudulent checks into the man’s credit union account to create funds for a multi-day shopping spree at Walmart. After a jury trial, he was convicted of seven of the offenses, including grand theft of retail goods and fraudulent use of a financial transaction card. On appeal, Coats contended the jury did not have substantial evidence to convict him of grand theft of retail goods from an owner because Walmart was paid in full for the goods, and Morgan, the man from whom he obtained the debit card, never owned the purchases. Alternatively, he argued he was subjected to double jeopardy upon being convicted for both grand theft and fraudulent use of a financial transaction card, because fraudulent use was a lesser included offense of grand theft. The Idaho Supreme Court determined there was not substantial evidence for the conviction of grand theft: "While Idaho’s theft statute is broad and covers many misdeeds, there must be a careful analysis of what was stolen and from whom before a charging decision is made and the jury is instructed." Because this case was remanded to the district court with instructions to vacate Coats’s conviction on grand theft, the Supreme Court did not reach the merits of Coats’s double jeopardy argument. "[I]f the State desired to charge Coats for grand theft relating to the purchases made at Walmart with a debit card, it had to properly allege Coats wrongfully obtained money from the credit union that credited Morgan’s account with funds for the POS transaction. Yet, the State charged Coats with wrongfully obtaining retail goods from an owner—there was not sufficient evidence presented for a jury to convict Coats of this specific crime." View "Idaho v. Coats" on Justia Law