Jones v. Commonwealth (1978)
In Jones v. Commonwealth, 218 Va. 757, 240 S.E.2d 658 (Va. 1978), the evidence showed that the defendant entered a motel office and forced the clerk to surrender both money and the keys to the motel's courtesy car.
The defendant then left the motel office and proceeded to steal the motel's courtesy car, which was located two hundred yards from the motel office. See 240 S.E.2d at 660.
The court affirmed the defendant's multiple convictions, stating that the "larceny of the car, located two hundred yards away from the scene of the first theft, and the act underlying that offense occurred at a different place at a later point in time." Id. at 661.
Thus, the court concluded that "the two thefts involved two separate and distinct acts of caption and two different acts of asportation." Id.