False Pretenses

Under common law, a defendant commits the crime of false pretenses when by making an intentional statement with intent to defraud the victim he obtains title to the personal property of the victim. For a defendant to be convicted of this crime, the intentional false statement he makes to the victim must reference a past or present fact or event, a false statement regarding the future or some sort of future promise would not suffice to satsify that element of the crime. False pretenses differs from larceny in that title, and not just possession of the victim's personal property is obtained by the defendant.