Justina Alice Dunne v. Commonwealth of Virginia, 782 S.E.2d 170

Justina Alice Dunne, a VMI student, was convicted by a Rockbridge County jury under Va. Code § 18.2-461(i) for knowingly giving a false report of a crime to law-enforcement with intent to mislead.
Original incident: another student reported $120 missing from a dorm lockbox; Dunne reported $20 missing from her wallet. VMI officer Coffey responded and handled evidence.
Dunne later told a non-law-enforcement third party that Officer Coffey had conducted invasive searches including digital vaginal and anal penetration; that third party reported it to VMI, and the Virginia State Police began an investigation.
Dunne gave a recorded interview to a Virginia State Police special agent (with counsel present) in which she described the alleged search in detail and characterized herself as a victim of sexual assault; the agent warned her the matter was serious and could lead to criminal charges against the officer.
The State’s investigation found no corroboration; Dunne was charged with false reporting and acquitted of petit larceny. She was convicted of the false-reporting misdemeanor, sentenced to 90 days and fined, and appealed on sufficiency grounds.

Issue	Plaintiff's Argument (Dunne)	Defendant's Argument (Commonwealth)	Held
Whether Dunne's allegation described the commission of "any crime" under § 18.2-461(i)	Her story described a Fourth Amendment violation or an invasive search but did not allege a crime under Virginia law (e.g., no force, threat, ruse; consent negates some offenses).	False reporting need only allege the commission of a crime; it need not be a perfect fit to a Virginia criminal statute — "any crime" includes federal crimes such as deprivation of rights under color of law (18 U.S.C. § 242).	The court held the allegation sufficiently described the commission of a crime (including a federal crime), satisfying § 18.2-461(i).
Whether Dunne "gave a report" to a law-enforcement official as required by § 18.2-461(i)	She did not originate the tip to police, initially declined to speak, and only answered questions; thus she did not "report" a crime.	A "report" is any detailed account or statement giving information; Dunne knowingly gave a detailed account to a state police special agent who identified himself and warned of criminal consequences.	The court held Dunne’s detailed, voluntary interview with a state police special agent constituted a "report."

Jones v. Commonwealth, 276 Va. 121, 661 S.E.2d 412 (review standard for sufficiency of evidence)
Ainslie v. Inman, 265 Va. 347, 577 S.E.2d 246 (statutory interpretation reviewed de novo)
Bd. of Supervisors of James City Cty. v. Windmill Meadows, LLC, 287 Va. 170, 752 S.E.2d 837 (plain-meaning rule for statutes)
Commonwealth v. Leone, 286 Va. 147, 747 S.E.2d 809 (statutory interpretation principles)
Nicholson v. Commonwealth, 56 Va. App. 491, 694 S.E.2d 788 (courts may not add or subtract statutory words)
Posey v. Commonwealth, 123 Va. 551, 96 S.E. 771 (traditional rule against judicial addition to statutes)
Jackson v. Fidelity & Deposit Co., 269 Va. 303, 608 S.E.2d 901 (courts must adhere to statutory language)