Caminade v. Commonwealth

James M. Caminade was convicted, in a bench trial, of three statutory burglaries and one attempted burglary. We granted an appeal limited to the question whether the evidence was sufficient to support his convictions of the three burglaries. We conclude that it was sufficient to support two of the convictions but insufficient to support the third.

During September and early October 1983, the police had received complaints of 68 burglaries and attempted burglaries in the Denbigh area of Newport News. The modus operandi seemed uniform: all were committed between approximately midnight and dawn,…