## Facts

- A neighbor observed a man twice leaning into the driver’s side window of a work truck parked under a garage light around 2 a.m.; she viewed him from behind, without corrective glasses, and could not reliably identify him.
- About an hour later, police stopped Ramiro Jaime Reyes for speeding and found a toolbox, a cellular phone, and identification badges belonging to the truck’s owner in Reyes’s car.
- The truck owner reported the items were missing from his truck; the driver’s side window was down, though the owner was unsure whether he left it down.
- Police arranged an in-field identification in which Reyes, handcuffed, exited a patrol car while the neighbor viewed him from her doorway or porch; she identified him as the person she had seen near the truck.
- Reyes was charged with vehicular burglary and receiving stolen property; the burglary count was dismissed at trial for lack of proof the truck was locked.
- At trial on receiving stolen property, Reyes testified he was heavily intoxicated, found the items on the roadside, and believed they were discarded.
- The defense presented evidence of Reyes’s substance abuse and intoxication and sought psychologist testimony that Reyes’s substance abuse and mental disorders impaired his ability to know the property was stolen.
- The trial court excluded the psychologist’s opinion and restricted intoxication-related proof on the theory that such mental-state evidence was unavailable for a general-intent offense.

## Issues

1. Whether evidence of voluntary intoxication is admissible to negate the knowledge element (“knew the property was stolen”) of receiving stolen property under Penal Code § 496(a).
2. Whether evidence of mental disease, defect, or disorder is admissible to rebut proof that the defendant actually possessed the required knowledge element, notwithstanding the offense’s general-intent classification.
3. Whether exclusion of the defense mental-state evidence was prejudicial error requiring reversal.

## Decision

- The Court of Appeal reversed the conviction and remanded for further proceedings.
- The court held that evidence of voluntary intoxication and mental disorder was admissible to contest whether Reyes actually knew the property was stolen.
- The trial court erred by categorically excluding the expert mental-disorder opinion and limiting related evidence based solely on the “general-intent” label.
- The error was prejudicial because the excluded evidence went to the central disputed element of knowledge and was the core of the defense.

## Legal Principles

- Receiving stolen property under Penal Code § 496(a) requires proof beyond a reasonable doubt that the defendant actually knew the property was stolen.
- Penal Code §§ 22 and 28 restrict the uses of intoxication and mental-disorder evidence, but they do not justify a blanket exclusion where the proffered evidence is relevant to an express mental element the prosecution must prove.
- Voluntary intoxication evidence may be admitted when it bears on whether the defendant actually harbored a statutorily required mental state, including knowledge.
- Mental disease, defect, or disorder evidence may be admitted to show the defendant did not in fact form a required mental state, so long as it is used to rebut the prosecution’s proof of that element rather than as a standalone diminished-capacity defense.
- Excluding admissible mental-state evidence that is central to disputing an essential element is prejudicial when there is a reasonable probability the result would have been different had the jury heard it.

## Conclusion

The appellate court held that both voluntary intoxication and mental-disorder evidence were admissible to dispute whether Reyes knew the property was stolen, and it reversed because the trial court’s categorical exclusion of that evidence undermined the defense on the key element of knowledge.


People v. Reyes, 52 Cal. App. 4th 975, 61 Cal. Rptr. 2d 39 (Cal. Ct. App. 1997)