Va. Code » Title 18.2. Crimes and Offenses Generally » Chapter 5. Crimes Against Property » Article 3. Larceny and Receiving Stolen Goods
Virginia Code

Va. Code Ann. § 18.2-103 (2026)

Concealing or taking possession of merchandise; altering price tags; transferring goods from one container to another; counseling, etc., another in performance of such acts

✓ current as of May 2026
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Whoever, without authority, with the intention of converting goods or merchandise to his own or another's use without having paid the full purchase price thereof, or of defrauding the owner of the value of the goods or merchandise, (i) willfully conceals or takes possession of the goods or merchandise of any store or other mercantile establishment, or (ii) alters the price tag or other price marking on such goods or merchandise, or transfers the goods from one container to another, or (iii) counsels, assists, aids or abets another in the performance of any of the above acts, when the value of the goods or merchandise involved in the offense is less than $1,000, shall be guilty of petit larceny and, when the value of the goods or merchandise involved in the offense is $1,000 or more, shall be guilty of grand larceny. The willful concealment of goods or merchandise of any store or other mercantile establishment, while still on the premises thereof, shall be prima facie evidence of an intent to convert and defraud the owner thereof out of the value of the goods or merchandise.

Code 1950, § 18.1-126; 1960, c. 358; 1970, c. 652; 1975, cc. 14, 15; 1994, c. 706; 2018, cc. 764, 765; 2020, cc. 89, 401.

Notes of Decisions
Cited in 59 cases (9 in the last 5 years), 1976–2025 · leading case: Hulcher v. Commonwealth, 575 S.E.2d 579 (Va. Ct. App. 2003).
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Hulcher v. Commonwealth, 575 S.E.2d 579 (Va. Ct. App. 2003). · cites it 23× “Mark Thomas Hulcher (appellant) appeals from his bench trial conviction for concealment pursuant to Code § 18.2-103. On appeal, he contends the statute proscribes only the theft of *603 “wares offered for sale” and does not include items not offered for sale, such as items used…”
Snead v. Commonwealth, 400 S.E.2d 806 (Va. Ct. App. 1991). · cites it 18× “The appellant, Alice Marie Snead, was convicted in a bench trial for a third offense of willful concealment of merchandise under Virginia Code §§ 18.2-103 and 18.2-104. On appeal, she raises four questions: (1) whether the evidence was sufficient, as a matter of law, to prove…”
Welch v. Commonwealth, 425 S.E.2d 101 (Va. Ct. App. 1992). · cites it 16× “These statutes now allow proof of larceny in those instances where (1) goods were concealed while on the premises of another, Code § 18.2-103(i), (2) identifying marks were altered or deleted, Code § 18.”
Lindsey v. Commonwealth, 795 S.E.2d 311 (Va. 2017). · cites it 8× “2-103 provides: Whoever, without authority, with the intention of converting goods or merchandise to his own or another's use without having paid the full purchase price thereof, or of defrauding the owner of the value of the goods or merchandise, (i) willfully conceals or takes…”
Johnson v. Commonwealth, 543 S.E.2d 605 (Va. Ct. App. 2001). · cites it 12× “Carol Bowyer Johnson appeals her conviction, after a bench trial, of misdemeanor concealment of merchandise, in violation of Code § 18.2-103. Johnson argues the evidence was insufficient to support the conviction.”
Harris v. Commonwealth, 477 S.E.2d 3 (Va. Ct. App. 1996). · cites it 12× “The predicate offenses that enhanced the sentence of a defendant were expressly limited to shoplifting under Code § 18.2-103 or a "like offense," grand larceny under Code § 18.”
Brittle v. Commonwealth, 680 S.E.2d 335 (Va. Ct. App. 2009). · cites it 2× “On November 8, 2007, Jonathan Brittle was convicted of petit larceny, third offense in violation of Code §§ 18.2-103 and 18.2-104. On appeal, Brittle argues that two of the three prior conviction orders admitted by the Commonwealth are insufficient to prove that he had been…”
Williams v. Commonwealth, 649 S.E.2d 717 (Va. Ct. App. 2007). · cites it 4× “For example, one obvious result of accepting the Commonwealth's argument would be that every concealment of merchandise in violation of Code § 18.2-103, regardless of the item's value, would also constitute a Class 5 felony under Code § 18.”
Edwards v. Commonwealth, 672 S.E.2d 894 (Va. Ct. App. 2009). · cites it 4× “would be that every concealment of merchandise in violation of Code § 18.2-103, regardless of the item's value, would also constitute a Class 5 felony under Code § 18.”
United States v. Osborne, 514 F.3d 377 (4th Cir. 2008). “” Va. Code Ann. § 18.2-103 . By contrast, Virginia defines its insufficient funds check offense, in relevant part, as follows: Any person who, with intent to defraud, shall make or draw or utter or deliver any check, draft, or order for the payment of money, upon any bank,…”
Pittman v. Commonwealth, 434 S.E.2d 694 (Va. Ct. App. 1993). · cites it 3× “On appeal from his felony conviction of a third or subsequent offense of concealing merchandise in violation of Code §§ 18.2-103 and 18.2-104(b), James Henry Pittman contends that the trial court erred (1) in admitting into evidence orders reflecting six prior convictions of…”
Hudson v. Commonwealth, 383 S.E.2d 767 (Va. Ct. App. 1989). · cites it 5× “A jury convicted Ernest Lee Hudson of larceny by concealment, a violation of Code § 18.2-103; The Commonwealth offered certified copies of three prior convictions of Hudson for like offenses to show that he was eligible for enhanced punishment under Code § 18.”
Show all 59 citing cases →
— Va. Code Ann. § 18.2-103(i) — 2 cases
Welch v. Commonwealth, 425 S.E.2d 101 (Va. Ct. App. 1992). “These statutes now allow proof of larceny in those instances where (1) goods were concealed while on the premises of another, Code § 18.2-103(i), (2) identifying marks were altered or deleted, Code § 18.”
Gene Raymond Locke v. Commonwealth of Virginia (Va. Ct. App. 2022).
— Va. Code Ann. § 18.2-103(ii) — 2 cases
Welch v. Commonwealth, 425 S.E.2d 101 (Va. Ct. App. 1992). “These statutes now allow proof of larceny in those instances where (1) goods were concealed while on the premises of another, Code § 18.2-103(i), (2) identifying marks were altered or deleted, Code § 18.”
Gene Raymond Locke v. Commonwealth of Virginia (Va. Ct. App. 2022).
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