People v. Showers

In People v. Showers (1968) 68 Cal.2d 639, the defendant was seen searching for something in an ivy patch in which a balloon of heroin was found. He testified at a bench trial that he was looking for money that another person told him was lost in the ivy. The California Supreme Court held there was substantial evidence of defendant's consciousness of guilt based in part on that testimony: "There is substantial evidence which meets the two requirements of guilty knowledge. Defendant was searching for something in the ivy. He testified that he was looking for the $ 50 which Larry Oliver told him he had lost. ... No money was found, nor did the trial judge believe that any money was ever lost. In the circumstances defendant's explanation for his three visits to the ivy patch could be found by the trier of fact to be a fabrication. False statements regarding incriminating circumstances constitute evidence which may support an inference of consciousness of guilt." (Id. at p. 643.)