Black v. Commonwealth

In Black v. Commonwealth, 20 Va. App. 186, 190, 455 S.E.2d 755, 757 (1995), which involved a robbery at the Providence Savings and Loan Association, an employee testified that his association offered "services such as checking accounts, savings accounts, and loans," performing banking services for its customers. Black contended the savings and loan was not a bank and, therefore, not a "banking house" under Code 18.2-93. The Court held, based on the employee's testimony, the savings and loan association was a "banking house." Id. at 191, 455 S.E.2d at 758. The Court reasoned: To construe the statute as appellant suggests would require us to conclude that the intent of the legislature was to punish armed entry into a "bank," but not to punish armed entry into a "savings and loan association." Such an interpretation is contrary to the legislative intent and requires "an unreasonably restrictive interpretation of the statute."Id. at 191, 455 S.E.2d at 757.