Virginia Code

Va. Code Ann. § 18.2-178 (2026)

Obtaining money or signature, etc., by false pretense

✓ current as of May 2026

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A. If any person obtain, by any false pretense or token, from any person, with intent to defraud, money, a gift certificate or other property that may be the subject of larceny, he shall be deemed guilty of larceny thereof; or if he obtain, by any false pretense or token, with such intent, the signature of any person to a writing, the false making whereof would be forgery, he shall be guilty of a Class 4 felony.

B. Venue for the trial of any person charged with an offense under this section may be in the county or city in which (i) any act was performed in furtherance of the offense, or (ii) the person charged with the offense resided at the time of the offense.

Code 1950, § 18.1-118; 1960, c. 358; 1975, cc. 14, 15; 2001, c. 131; 2006, c. 321.

Notes of Decisions

Cited in 149 cases (28 in the last 5 years), 1975–2026 · leading case: Angela Maye Holt v. Commonwealth of Virginia, 783 S.E.2d 546 (Va. Ct. App. 2016).

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Angela Maye Holt v. Commonwealth of Virginia, 783 S.E.2d 546 (Va. Ct. App. 2016). · cites it 23× “At the conclusion of a jury trial, Angela Maye Holt was convicted of obtaining money by false pretenses in violation of Code § 18.2-178 and embezzlement in violation of Code § 18.”

Moore v. Commonwealth, 722 S.E.2d 668 (Va. Ct. App. 2012). · cites it 20× “2-181, three counts of obtaining money by false pretenses under Code § 18.2-178, and three counts of uttering a forged writing under Code § 18.”

Gardner v. Commonwealth, 546 S.E.2d 686 (Va. 2001). · cites it 12× “Code § 18.2-178. [1] The trial court, sitting without a jury, convicted the defendant of the charge *687 and sentenced her to serve three years in the penitentiary.”

Shropshire v. Commonwealth, 577 S.E.2d 521 (Va. Ct. App. 2003). · cites it 12× “Shropshire was charged in an indictment with grand larceny by false pretenses from Oakridge Toyota in violation of Code § 18.2-178. At trial, the $4,200 check was introduced into evidence.”

Storey v. Patient First Corp., 207 F. Supp. 2d 431 (E.D. Va. 2002). · cites it 12× “(2) Va.Code §§ 18.2-178 And 18.2-260.1 Storey also points to Va.”

Michels v. Commonwealth, 624 S.E.2d 675 (Va. Ct. App. 2006). · cites it 4× “Robert Michels (appellant) appeals his conviction by a jury of three counts of obtaining money by false pretenses in violation of Code § 18.2-178. He argues that the introduction of documents from the Delaware Secretary of State, which certified that two entities were not…”

Joaquin Shadow Rams, Sr., a/k/a, etc. v. Commonwealth of Virginia, 823 S.E.2d 510 (Va. Ct. App. 2019). · cites it 2× “had a seizure that day came from the 4 The appellant also was convicted of attempted false pretenses in violation of Code § 18.2-178. This conviction stemmed from misrepresentations that he made when he applied for the insurance on the child’s life.”

Austin v. Commonwealth, 723 S.E.2d 633 (Va. Ct. App. 2012). · cites it 6× “Sandra Lee Austin (“Austin”) appeals her conviction after a bench trial in the Circuit Court of the City of Charlottesville (“trial court”) of two counts of obtaining money or property by false pretense in violation of Code § 18.2-178. On appeal, Austin argues that the trial…”

Bray v. Commonwealth, 388 S.E.2d 837 (Va. Ct. App. 1990). · cites it 10× “The second issue is whether one can be convicted of larceny by false pretenses, Code § 18.2-178, for giving a worthless check for the advance payment of the first month’s rent on residential real estate and, in return, receiving the key to the premises.”

Mosteller v. Commonwealth, 279 S.E.2d 380 (Va. 1981). · cites it 14× “Tried by the court, sitting without a jury, on indictments charging him with grand larceny from the Commonwealth in violation of Code § 18.2-178, 1 David Mosteller was found guilty on eight separate counts.”

Parks v. Commonwealth, 270 S.E.2d 755 (Va. 1980). · cites it 2× “, was tried before a jury and convicted on two indictments for grand larceny charging obtaining money by false pretenses, Code § 18.2-178. He was sentenced to serve twelve months in jail and fined $1,000 on each charge.”

Nijhawan v. Holder, 557 U.S. 29 (2009). “, Va. Code Ann. §§ 18.2-178 , 18.2-95, 18.2-195 (Lexis 1996).”

Show all 149 citing cases →

— Va. Code Ann. § 18.2-178(A) — 12 cases

Angela Maye Holt v. Commonwealth of Virginia, 783 S.E.2d 546 (Va. Ct. App. 2016). “At the conclusion of a jury trial, Angela Maye Holt was convicted of obtaining money by false pretenses in violation of Code § 18.2-178 and embezzlement in violation of Code § 18.”

Austin v. Commonwealth, 723 S.E.2d 633 (Va. Ct. App. 2012). “Sandra Lee Austin (“Austin”) appeals her conviction after a bench trial in the Circuit Court of the City of Charlottesville (“trial court”) of two counts of obtaining money or property by false pretense in violation of Code § 18.2-178. On appeal, Austin argues that the trial…”

Charles P. Adkins & Jane E. Adkins v. United States, 113 Fed. Cl. 797 (Fed. Cl. 2013).

Thomas Khaled Maad v. Commonwealth of Virginia (Va. Ct. App. 2021).

Daniel Carlton Railey v. Commonwealth of Virginia (Va. Ct. App. 2024).

— Va. Code Ann. § 18.2-178(B) — 2 cases

Kelso v. Com., 710 S.E.2d 470 (Va. 2011).

Commonwealth v. Napier, 93 Va. Cir. 446 (Buchanan Cir. Ct. 2016).

— Va. Code Ann. § 18.2-178(a) — 1 case

Levar Donnie Richardson v. Commonwealth of Virginia (Va. Ct. App. 2010).

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