People v. Staples – Case Brief (IRAC Format)

⚖️ People v. Staples (1970)

Court: 2d Appellate Dist., Div. 5 Cal.
Date: March 27, 1970
Citation: 6 Cal. App. 3d 61
Author: Thompson

❓ Issue

Had defendant’s acts passed mere preparation and become an attempt to burgle under California law?

📘 Rule

Cal. Pen. Code § 664:

  • The specific intent to commit a crime, and
  • The direct unequivocal act which if not for the impossibility of burglary being achieved, would have completed the crime.

⚖️ There is an important difference between preparation and attempt in criminal law.
📚 The rule is: a person is not guilty of attempt if they have only prepared to commit a crime. But, as soon as the person begins to do something that is more than just preparation toward the crime, they can be charged with attempt—even if the crime is not finished.

🕰️ Facts

In October 1967, Dr. Staples, a mathematician, rented an office in a commercial building in Hollywood, California. The office was above the mezzanine level of a bank and above the vault of the bank.

At no time from the outset did Staples have a legitimate business purpose for renting the space. He selected the location because it was near the vault. He paid rent for the period of October 23 to November 23, but the landlord needed 10 days to complete repairs and painting before he could move in.

Within those 10 days—before the rental period officially began—he brought in various tools of burglary:

  • Two acetylene gas tanks, a blow torch, drilling equipment, a linoleum rug, a blanket, a lock and hasp, he stored inside a closet, which he secured with a hasp lock that he installed himself; while inspecting the repairs, the landlord observed the equipment but didn’t immediately report.

On Saturday, October 14, Staples drilled two sets of holes in the floor of his office right above the bank vault, covered the holes with linoleum, returning several times over the following weeks to continue work. He was aware the building was unoccupied on Saturdays and chose to drill then.

Shortly afterward, he forgot his keys at the office. Finding them, the landlord unlocked the door, saw the equipment, and called the police.

📅 Staples was arrested on February 22, 1968. After being properly advised of his Miranda rights, he voluntarily provided a written statement, clearly indicating his intention to burglarize the vault.

The main legal question is whether the actions of Staples were just getting ready, or if they had proceeded to the point of trying to commit a break-in.

✅ Specific Intent

There is no dispute over the intent of Staples. His confession proves that he wanted to drill into the vault and take money. Intent was further evidenced by:

  • Having strategically rented the office location above the vault
  • Having chosen tools that are meant for breaking into a secure space

His precautions to hide the crime (e.g., drilling on weekends, covering holes)

🔧 Beyond Mere Preparation

Under California law, gathering tools and scouting a space is preparation. However, Staples:

  • Drilled through the floor right above the vault
  • Installed a lock to hide his tools
  • Came back to keep changing the floor
  • Tried to make an undetectable entry point
  • Had not voluntarily stopped his efforts - he was interrupted

This constituted "a direct movement toward the commission of the crime" and not mere preparation.

❌ Not a Voluntary Change of Mind

Staples did not change his mind or decide to give up his plan. Rather, his scheme was interrupted by discovery and arrest. The court emphasized that while in some cases voluntary withdrawal may negative criminal attempt, such was not the case here.

✅ Conclusion

Revised Text:
The Staples drilled activities were held to vividly manifest not just preparation but attempt, hence the two main ingredients required for an attempt:

  • The specific criminal intent,
  • And
  • Direct acts that advance the crime.

The conviction for attempted burglary was upheld. Staples' drilling activities and concealment of tools and written confession proved attempt, not just preparation.

🧠 Key Takeaways

  • 🔍 The line between preparation and attempt is crossed when actions show a clear, forward movement in committing the crime.
  • A confession can be very strong to support intent, especially when there is some other evidence.
  • Voluntary abandonment might make someone not guilty for the attempt—but this has to be real and done by the person.
  • In crimes where there is a plan and tools (like burglary), using the tool and aiming at a place are very important in the attempt.


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