Alphonso N. Owens v. United States

FISHER, Associate Judge:

After a jury trial, appellant Alphonso Owens was convicted of receiving stolen property (RSP) 1 and unauthorized use of a vehicle (UUV). 2 On appeal, he argues that a supplemental instruction responding to a note from the jury constituted reversible error. Although the instruction was not an ideal explanation of the subjective knowledge required for RSP, appellant has not shown plain error, and we affirm his convictions.

I.Factual Background

On September 14, 2011, officers from the Metropolitan Police Department’s (MPD) auto theft unit located a 1996 gold Nissan Maxima…