Nashville, Tenn. - Today, the Tennessee Supreme Court issued an opinion in State of Tennessee v. Ronald Matthew Lacy, affirming Lacy’s conviction for theft of property over $60,000.
In 2015, Lacy, a luxury car broker in Kentucky, persuaded Christopher Dyer, the owner of a car dealership in Lenoir City, Tennessee, to wire him funds for a Mercedes. The deal was negotiated through text messages and emails that Lacy sent from Kentucky. Lacy represented that his company had the right to sell the Mercedes to Dyer, but neither Lacy nor his company ever owned the Mercedes. And Lacy never delivered the Mercedes to Dyer or returned Dyer’s money.
A Loudon County jury convicted Lacy of theft. Lacy moved for a new trial, arguing that Tennessee lacked territorial jurisdiction and that the State failed to prove that he obtained Dyer’s money without Dyer’s effective consent. The trial court rejected those arguments. The Court of Criminal Appeals affirmed Lacy’s conviction. The Tennessee Supreme Court granted Lacy’s permission to appeal from that decision.
The Tennessee Supreme Court affirmed Lacy’s conviction.
First, the Court held that Tennessee had statutory territorial jurisdiction to convict Lacy of theft. Territorial jurisdiction concerns a State’s authority to punish criminal conduct that occurs within its borders. In Tennessee, a statute grants territorial jurisdiction over an out-of-state defendant who consummates a crime in Tennessee using electronic means. The Court concluded that this statute provided territorial jurisdiction in Lacy’s case because Lacy used electronic means—text messages and emails—to complete the theft offense by persuading Dyer to send him money.
Second, the Court held that the evidence presented at trial was sufficient to support Lacy’s theft conviction because it established that Lacy obtained Dyer’s money without Dyer’s effective consent. By statute, consent is ineffective if it is induced through deception. The Court concluded that the evidence in this case was sufficient to prove that Lacy induced Dyer to send him money by falsely claiming that he had the right to sell the car.
To read the Court’s opinion, authored by Justice Sarah K. Campbell, please visit the opinions section of TNCourts.gov.