Overstreet v. Commonwealth

Opinion

KOONTZ, J.

Carlton Alford Overstreet (Overstreet) appeals from his conviction pursuant to Code § 18.2-102 for the unauthorized use of a motor vehicle. Overstreet contends that, as he originally had consensual possession of the vehicle, his retention of the vehicle beyond the time agreed to by its owner amounted to a simple conversion rather than a trespassory taking. Whether Code § 18.2-102 is applicable where the defendant’s possession or use of a motor vehicle was initially authorized by the owner, but possession or use of it thereafter extended beyond the scope of the owner’s…