RICHMOND, Va. (WRIC) – A Virginia man was convicted of using a movie prop $20 bill at a convenience store to buy a six-pack of beer in 2023.
An appeals court sided with him over the state Tuesday, reversing his conviction after finding the bill wasn’t technically a forgery under Virginia law because it “purported to be fake money to be used as a prop in a movie” and was “invalid on its face.”
The case came after Jeffrey Reeves Joyce Jr. went to a convenience store in April 2023 and purchased a six-pack of beer using the movie prop bill.
Even though the bill felt “weird” and was “thicker” and “lighter” than a regular bill, the cashier accepted it and gave Joyce change — which Joyce used to buy another item, according to the Nov. 12 order from a three-judge panel of the Court of Appeals of Virginia.
The cashier checked the bill again a few minutes later and realized it wasn’t real. The cashier called the manager to tell them, who marked it with a counterfeit pen and found it wasn’t genuine money.
“To the left of Andrew Jackson’s smirking face was printed ‘This note is for motion picture purposes, it is not legal tender.’ ‘Motion Picture Purposes’ was printed three more times on the front in place of ‘The United States of America,’ ‘Federal Reserve Note,’ and ‘Jackson,’” the appeals court panel’s order reads.
On the back of the bill, “Motion Picture Purposes” was printed above the White House, and “In Props We Trust” was put in place of “The United States of America” and “In God We Trust,” per the court order.
Joyce was eventually charged with obtaining money by false pretenses and forging coin or bank notes, a felony, by uttering or attempting to employ a fake bill as true, according to the appeals court’s order.
He moved to strike the uttering charge, arguing that the bill “very plainly on its face is not U.S. currency” so it wasn’t technically counterfeit,” per the court order.
The motion was overruled by the trial court and Joyce was found guilty of both offenses. Per the appeals court’s order, the trial “court found that ‘there’s no question that’ Joyce used ‘a false bill’ and that ‘[t]he only thing that could possibly be argued is whether he knew it to be false.’”
Per the appeals court’s order, the trial court said the bill “was ‘obviously fake’ such that ‘anybody who holds it knows.’”
Joyce was sentenced to five years for the felony, with all of it suspended, and eventually appealed. He didn’t appeal his misdemeanor conviction for obtaining property by false pretenses and was sentenced to a year in jail with 11 months suspended for the misdemeanor conviction, per the court order.
Someone can violate the law on forging money in Virginia in three ways. They can forge any coin, note or bill, make a fraudulent one or “utter, or attempt to employ as true, . . . any such false, forged, or base coin, note or bill, knowing it to be so,” per the appeals court’s order.
The state, represented by the attorney general’s office, argued that Joyce violated the uttering subsection “by ‘employ[ing] as true’ a bill that resembled the genuine article enough ‘to deceive the cashier,’” per the appeals court’s order.
“Joyce counters, as he did below, that the prop bill was not ‘such false, forged, or base coin, note or bill’ referenced in the statute. We agree with Joyce,” the appeals court panel wrote.
The appeals court panel found the prop bill in the case was not illegal to make or that it was forged, asserting that it didn’t meet the definition of “forgery” in the state code.
“Here, the prop bill stated expressly that ‘it [wa]s not legal tender’ on the front and displayed the words ‘Motion Picture Purposes’ four times on the front and once on the back, including three times in large, conspicuous block letters. Thus, the bill was invalid on its face, rendering it not a forgery” under state law,” the panel wrote.
The appeals court panel said it was unpersuaded by the attorney general office’s argument that the bill was a forgery because it deceived the store’s cashier, finding that the cashier accepting it and then realizing it was fake later doesn’t prove it was “made with the intent and ability to deceive.”
“That this particular statute does not prohibit Joyce’s conduct does not mean that such conduct was legal, as demonstrated by his unchallenged conviction of obtaining money by false pretenses under” Virginia code, the panel wrote.