Va. Court of Appeals

McEachern v. Commonwealth: If you take a car it can be inferred that you intend to steal it; a stolen item is taken with intent to not allow the victim to have it back (as opposed to unauthorized use, a lesser felony). Specifically, if you announce that you intend to force someone into their own car and take them somewhere to kill them and they run away, you have still taken the car without the intent to return it to its owner when you drive away with the car.