Steven Lawrence Sykes v. Commonwealth of Virginia

CLEMENTS, Judge.

Steven Lawrence Sykes was convicted in a bench trial of five felony counts of issuing bad checks, third or subsequent offense of larceny, in violation of Code §§ 18.2-181 and 18.2-104. On appeal, Sykes contends the trial court erred in applying Code § 18.2-183’s evidentiary presumption of fraudulent intent to him because the checks he wrote in this case were drawn on closed, rather than nonexistent, bank accounts. Finding no error, we affirm the judgment of the trial court.

I. BACKGROUND

The relevant facts in this case are undisputed. Between November 5, 1999, and March 18,…