Grand Larceny Case In Virginia
In Lewis v. Commonwealth, 28 Va. App. 164, 503 S.E.2d 222 (1998), the defendant, who was convicted of grand larceny, claimed that a temporary certificate of ownership did not give him sufficient title to satisfy the elements of grand larceny. See id. at 168, 503 S.E.2d at 223.
In rejecting that argument, we stated that possession of the car and a conditional title were enough to justify a conviction for grand larceny. See 28 Va. App. at 168-69, 503 S.E.2d at 223-24.
To decide otherwise would "'reward the industrious and designing thief who, having perpetrated the proper fraud by making false representations, could escape criminal liability as long as the official title remained with the owner in security.'" Id. at 169, 503 S.E.2d at 224 (quoting State v. Meado, 163 Wis. 2d 789, 472 N.W.2d 567, 571 (Wisc. Ct. App. 1991)).