Supreme Court of Virginia

Frank L. Parks, Sr. v. Commonwealth of Virginia

October 10, 1980221 Va. 492

Summary

The Supreme Court of Virginia affirmed Frank L. Parks, Sr.'s jury convictions on two counts of obtaining money by false pretenses. The court held that Parks, although the nominal lessee of the building where police observed vehicle identification numbers, had no legitimate expectation of privacy in the premises and therefore could not challenge the warrantless observations under the Fourth Amendment. It further held that the circumstantial evidence linking the 'salvaged' cars Parks purchased in Georgia to stolen vehicles sold to two buyers was sufficient to prove guilt beyond a reasonable doubt. No separate opinions were filed.