People v. Kyllonen

In People v. Kyllonen, 402 Mich 135; 262 NW2d 2 (1978), the Supreme Court of Michigan addressed the application of a prior version of MCL 750.535; MSA 28.803 to thieves who conceal stolen property. The statute in question in the present case, MCL 600.2919a; MSA 27A.2919(1), mirrors the prior version of MCL 750.535; MSA 28.803. Specifically, the Supreme Court addressed the issue whether the criminal statute, which proscribed "aiding in the concealment of . . . stolen property," was intended to exclude thieves who conceal property they have stolen. Id. at 139-140, 148. The Court stated that the statute was "directed towards those who assist the thief or others in the disposition or concealment of stolen property." Id. at 145. The Court further stated that "to interpret the words 'buys', 'receives' or 'aids in the concealment' of stolen property to mean buying or receiving from one's self or aiding one's self in concealment is needlessly to corrupt a forthright and harmonious statute." Id. The Court held that the statute excluded thieves who concealed property they have stolen. Id. at 148.