Commonwealth v. Mills
Supreme Judicial Court of Massachusetts
764 N.E.2d 854 (2002)
Relevant factsFree
Mills (defendant), a retired police officer receiving a disability pension conditioned on reporting income below a threshold, ran a private-investigation business while underreporting his income and submitting inflated bills to a public-defense agency for more hours than he actually worked; convicted on multiple larceny counts, he argued on appeal that filing false earnings reports and underreporting income didn't constitute theft.
IssueFree
Whether, when state law statutorily merges the crimes of larceny, embezzlement, and larceny by false pretenses, the prosecution only needs to prove the elements of one of these crimes in order to convict a defendant for theft.