Jessica A. Lihlakha v. United States

FERREN, Senior Judge:

On April 24, 2014, this court affirmed Jessica A. Lihlakha’s conviction for unlawful entry, and held that the evidence was sufficient to support her conviction of misdemeanor receipt of stolen property (RSP); but we remanded the record — not the case — to the trial court for further findings relevant to Lihlakha’s “return for reward” defense to the RSP charge. 1 In this case of first impression, we identified four elements necessary to establish the defense by negating the intent, required by statute at the time, 2 to prove RSP. We concluded that the defense will be…