State v. Bolden

Summary

The court held that the evidence was insufficient to prove the concealment element of tampering with physical evidence because the defendant left the damaged SUV uncovered, visible from the roadway, and facing the public street. Although the defendant may have intended to make the SUV less noticeable, intent to conceal did not establish that the vehicle was actually concealed. The court reversed the tampering conviction, directed entry of an acquittal on that charge, affirmed the judgment in all other respects, and left any resentencing to the trial court's discretion.