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1339

Evidence of Theft from Interstate Shipment—Proof of Value

In order to establish a felony under 18 U.S.C. § 659, it must be proven that the value of the stolen goods, chattels, money or baggage exceeds $100. The blanks of money orders, checks, stock certificates, etc. may be difficult to value. In these situations the thieves' market value is often used to show their value. See United States v. Jackson 576 F.2d 749 (8th Cir. 1978); United States v. Moore, 571 F.2d 154 (3d Cir. 1978); Tyers, 487 F.2d 828 (2d Cir. 1973); United States v. Ditata, 469 F.2d 1270 (7th Cir. 1972).

[cited in USAM 9-61.300]