Grimes v. Commonwealth
Annotate this CaseDefendant was convicted of statutory burglary in violation of Va. Code Ann. 18.2-91. Defendant appealed, arguing that the evidence was insufficient to support his conviction because the Commonwealth established only that he went into a crawl space underneath a dwelling house and failed to prove that he actually broke into and entered the actual house. The court of appeals upheld the conviction, concluding that the crawl space in this case constituted part of the dwelling house. The Supreme Court affirmed, holding that the crawl space was structurally part of the dwelling house, and therefore, the evidence was sufficient to sustain Defendant’s conviction of statutory burglary.
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