Criminal: Alleged evidentiary error deemed harmless

Where a man convicted of grand larceny of a motor vehicle argued the circuit court wrongly excluded video-recorded hearsay statements that went to his defense, but any error was harmless, his argument was rejected.

Background                                       

The circuit court convicted James G. League of grand larceny of a motor vehicle. League now appeals, contending that the trial court abused its discretion by excluding certain video-recorded hearsay statements.

Analysis

League never contested that he towed the three vehicles from the Chalk Level Road property. Eric Dollins (property owner) and Leland Morton (Jeep owner) both testified that they did not sell their vehicles or give anyone permission to take them. The trial court, as the factfinder, credited this uncontested testimony. Accordingly, the evidence established that League took the vehicles without lawful authority.

League nonetheless contends that the Commonwealth failed to prove that he intended to steal the vehicles. He argues that the excluded hearsay statements that he bought the Jeep for parts “were highly material and relevant” because the trial court did not believe that anybody would offer League the vehicles for free. Thus, League claims, “[t]he proffered statements that [he] actually purchased the cars for parts directly undermined the [trial] [c]ourt’s rationale.”

This court disagrees. As noted above, the trial court’s reasoning began with its finding that League towed the vehicles from the Chalk Level Road property without the permission of the lawful owners. Thus, the trial court was entitled to conclude that League intended to steal the vehicles unless other circumstances negated that inference.

League appears to assert that some unknown person authorized him to take the vehicles, whether for payment or for free. But there is no evidence regarding this person’s identity, and League did not identify him or her in the proffered video clip. Nor is there any documentary evidence that League purchased the vehicles.

Given these circumstances, the trial court’s consideration of an additional video where League claimed he purchased the vehicles for parts would not have affected its conclusion that League stole them. Moreover, the admission of the September 2020 video would not have negated League’s other inconsistent or incredible statements regarding his acquisition of the vehicles.

In sum, the Commonwealth presented strong circumstantial evidence that League stole the vehicles, including multiple inconsistent and contradictory statements by League himself. Particularly given the trial court’s factual findings, this court cannot say that the introduction of an additional video clip of League claiming that he bought the vehicles would have affected the verdict. Accordingly, any possible error in excluding that video was harmless.

Affirmed.

League v. Commonwealth, Record No. 2170-23-2, Aug. 5, 2025. CAV (unpublished opinion) (White). From the Circuit Court of Louisa County (Cullen). (Steven Shareff; Steven Shareff, Attorney at Law, on brief), for appellant. (Jason S. Miyares, Attorney General; Justin M. Brewster, Assistant Attorney General, on brief), for appellee. VLW 025-7-210. 9 pp.