Is a defendant's actions subsequent to the crime proper evidence of his guilt?

New York courts have long held that a defendant's actions subsequent to a crime are proper evidence of his guilt. See People v. Conroy, 97 N.Y. 62, 80 (1884) (falsehoods and evasions to escape the imputation of crime may be considered by the jury on the issue of evil intent); People v. Pena, 50 N.Y.2d 400, 429 N.Y.S.2d 410, 406 N.E.2d 1347 (1980) (defendant's possession of a knife in a brown paper bag 20 minutes after incident where victim said defendant pointed bag at him and threatened to shoot is sufficient evidence to find that defendant possessed a "dangerous instrument" in commission of robbery). Further, it is an elementary principle that defendant's commission

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