Legal Definitions - single-larceny doctrine

The single-larceny doctrine is a legal principle in criminal law that addresses situations where a person steals multiple items of property. According to this doctrine, if a thief takes several items—even if they belong to different owners—at the same time and place, it is considered a single act of larceny (theft) rather than multiple separate thefts. This applies when the taking is part of one continuous plan or action, or if the thief gains control over all the items simultaneously. The crucial factor in determining whether there was one theft or multiple thefts is the thief's overall intent or plan.

Here are some examples to illustrate the single-larceny doctrine:

• Example 1: Theft of multiple items from one owner in a continuous act

  A burglar breaks into an unoccupied house. In one continuous sweep through the living room and kitchen, they grab a laptop from the coffee table, a tablet from the kitchen counter, and a valuable antique vase from a shelf, placing all items into a single bag before exiting the premises. Even though three distinct items were taken, they were all stolen from the same location (the house) during a single break-in and as part of one continuous act of theft. The burglar's intent was to steal from that house in one go, making it a single act of larceny under this doctrine.

• Example 2: Theft of items from different owners at the same event with a single plan

  During a crowded charity gala, a pickpocket moves through the reception area. As part of a pre-conceived plan to steal valuables, they discreetly remove a wallet from one guest's coat pocket, then moments later, take a smartphone from another guest's purse left on a nearby chair, and finally, pocket a pair of expensive cufflinks from a third guest's jacket draped over a railing. All these actions occur within a short timeframe in the same general area of the gala. Although items belonging to different individuals were stolen, they were taken from the same general location at essentially the same time, and as part of a single, continuous criminal intent to steal valuables from the event. Therefore, the single-larceny doctrine would likely apply, treating it as one theft.

• Example 3: Systematic theft of multiple items from a single large property

  An employee at a large electronics warehouse decides to steal merchandise. Over the course of an hour, while on duty, they systematically gather a high-end gaming console from one aisle, a drone from another section, and a smart television from the loading dock, concealing each item as they move through the facility, with the intention of taking all of them out at the end of their shift. Although the items were taken from different parts of a large warehouse, they were all stolen from the same overall "place" (the warehouse) during a single, continuous period of time, and as part of one overarching plan by the employee to steal multiple items from their employer. This would be considered a single act of larceny under the doctrine.