People v. Canadian Fur Trappers’ Corp. case brief

People v. Canadian Fur Trappers’ Corp. case brief summary
161 N.E. 455 (1928)

CASE SYNOPSIS

The defendant corporation appealed the judgment of the Appellate Division of the Supreme Court in the Fourth Judicial Department (New York), which affirmed the Erie County Court judgment convicting the defendant of the offense of larceny.

CASE FACTS
Defendant corporation was engaged in selling furs. The complainant purchased a fur coat on an installment plan, but when she submitted her final installment, defendant's employees attempted to give her a different coat. The coat she had actually selected was gone and had been resold to a third party. The defendant was charged with larceny, on the theory that the defendant's corporate officers instructed employees to resell the coats held on deposit and that this was the corporation's method of doing business. The defendant was convicted, and the conviction was affirmed on appeal. The defendant sought further view.

DISCUSSION

• In reversing and remanding for a new trial, the court concluded that the defendant was criminally liable only for such felonious acts that it authorized through its officers or for such acts that comprised its standards course of business and were thus implicitly authorized by them. 
• The prosecution failed to prove that the officers or any store manager had authorized a resale of the complainant's coat or that, if the complainant's coat had been resold, the resale of purchased coats was a continuous and established corporate practice.

CONCLUSION
The judgment affirming the defendant corporation's conviction was reversed, and the matter was remanded for a new trial.


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