Calvin Burnell Bailey, Jr. v. Commonwealth of Virginia, 0013161

Defendant Calvin Burnell Bailey, Jr. was convicted in the Circuit Court of the City of Norfolk of grand larceny for stealing a bicycle that was never recovered.
The bicycle owner testified the bike was purchased in Greece about 3.5 years earlier for $518, was in "excellent condition," and that replacement would cost about what he paid.
Bailey did not object at trial to testimony about purchase price, condition, or replacement cost.
Bailey moved to strike at the close of the Commonwealth’s case and at the end of all evidence, arguing the Commonwealth failed to prove the bicycle’s value met the $200 felony threshold.
The trial court denied the motions, convicted Bailey, and sentenced him to 1 year and 4 months; the Court of Appeals affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proved stolen bicycle valued at $200+ (element of grand larceny)	Commonwealth: owner’s testimony of purchase price and replacement cost supports value beyond $200	Bailey: owner’s testimony insufficient—replacement cost alone or purchase price without accounting for depreciation cannot establish value above statutory threshold	Court: Owner’s testimony of original purchase price plus opinion on replacement and condition permitted reasonable inference value ≥ $200; conviction affirmed

Parker v. Commonwealth, 254 Va. 118 (proof that value is element of grand larceny; original purchase price admissible as evidence of current value)
Walls v. Commonwealth, 248 Va. 480 (owner’s opinion of personal property value is admissible despite lack of market-expertise)
Baylor v. Commonwealth, 55 Va. App. 82 (replacement value alone insufficient where item has no market value; distinguishes cases involving regulated resale items)
Dunn v. Commonwealth, 222 Va. 704 (original purchase price must be adjusted for depreciation; owner testimony insufficient where condition/value not shown)