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State v. Waller
Citations: 312 S.E.2d 552; 280 S.C. 300; 1984 S.C. LEXIS 242Docket: 22042
Court: Supreme Court of South Carolina; February 14, 1984; South Carolina; State Supreme Court
Gregory Allen Waller was convicted of housebreaking and grand larceny, receiving a five-year prison sentence. He appealed the grand larceny conviction, arguing that the theft of property from multiple owners at the same time and place should be treated as separate larcenies unless the value from each owner meets the statutory minimum of $200. Waller acknowledged that the total value of the stolen items exceeded this threshold but contended that the individual values did not. The court, referencing South Carolina's intermediate legal doctrine, ruled that it is permissible for the state to aggregate the value of stolen property from different owners when prosecuted as a single larceny. Historical case law supports this interpretation, indicating that offenses of this nature can be prosecuted collectively rather than separately. The majority of jurisdictions uphold the principle that larceny from different owners at the same time and place constitutes a single larceny. The Supreme Court of South Carolina affirmed Waller's conviction, concluding that the evidence was sufficient for a jury to determine that the value of the property taken from at least one roommate exceeded $200. The ruling establishes that such cases will henceforth be prosecuted as single larcenies, regardless of the number of owners affected, provided the aggregate value meets the legal requirements.