Criminal – ‘Burglarious Tool’ – Empty Purse

By Deborah Elkins
Published: February 23, 2009

Although a woman admitted she emptied her large purse in order to conceal in it shoplifted store merchandise, the purse nevertheless was not a “burglarious tool” and her conviction under Va. Code § 18.2-94 is reversed by the en banc Court of Appeals. On appeal, defendant reiterates her argument that her purse is not a tool, ...

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