The defendant was convicted of obtaining utility services fraudulently by installing an illegal meter. The defendant argued that the evidence was not enough to prove it was worth more than $200, and the court erred in not striking the Commonwealth's case. The court found that the value of the services stolen was only the electricity used, not the additional costs associated with the service.
Penley v. Commonwealth (2008)
Court of Appeals of Virginia
51 Va. App. 166, 655 S.E.2d 746
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