Beiler v. Commonwealth

The issues in this case turn upon the sufficiency of the evidence and whether the defendant’s changes of the numerical amounts of two checks were alterations sufficiently material to constitute the common-law crime of forgery.

At a bench trial, Isabella Beiler was found guilty under Code § 18.2-172 of forging and uttering two checks and sentenced to one year in prison on each of the four counts. The sentences, imposed to run consecutively, were suspended, and Beiler was placed on probation for four years and ordered to make restitution.

Beiler appealed to the Court of Appeals. That Court…