MORENO V. COMMONWEALTH, 65 VA. APP. 121 (DECIDED AUGUST 11, 2015)

Whether defendant was properly convicted of uttering a forged public record in violation of Va. Code Ann. § 18.2-168. HOLDINGS: [1]-The circuit court did not err when it found that an accord and satisfaction letter presented by defendant to the general district court in an earlier matter, to have an assault and battery charge against defendant dismissed, fell within the statutory definition of a public record, under Va. Code Ann. § 42.1-77; [2]-Given that the jury decided that the document was forged and that defendant knew it to be a forgery, defendant was properly convicted of uttering a forged public record in violation of Va. Code Ann. § 18.2-168.

Outcome
Judgment affirmed.