Can Computer Time Be Stolen?

The Defendant was a graduate student at a state university working toward a Ph.D. When his faculty advisor's authorization for computer use lapsed, the Defendant continued running his dissertation computations using university computer time and keypunch-card services without authorization, obtaining printouts and cards along the way. He gained access using unauthorized account numbers and keys. The unauthorized computer time and services were valued at roughly $26,384. He was indicted for grand larceny. The Prosecution treated the misappropriated computer time and services — and the physical cards and printouts — as property that had been stolen. The Defense argued that Virginia's larceny statute reached only 'goods and chattels,' and that computer time and labor or services are not the kind of tangible personal property that can be taken and carried away.