State v. Banks

Defendant claimed error in his bench trial conviction for unlawful possession of a firearm in the first degree because the judge’s findings did not expressly include the element of knowledge as required by a case decided after his conviction. Because the court’s unchallenged written findings necessitate an inference of knowledge, we hold any error in the findings harmless beyond a reasonable doubt and affirm the conviction.

FACTS

On June 7, 1999, near a restaurant called The Hook, Line, and Sinker, the restaurant security guard observed Eric L. Banks in a heated discussion with some other…