## Facts

- Eagleton, a baker, contracted with local poor-relief authorities to supply loaves of a specified weight to impoverished persons presenting parish tickets.
- Eagleton delivered loaves that were materially underweight while representing them as meeting the contract specifications.
- Eagleton collected the tickets and submitted them with a statement of loaves supplied to the relieving officer.
- Based on Eagleton’s submissions, the relieving officer credited Eagleton in the parish account books; payment would ordinarily follow from the credited amount.
- Before any cash was paid, the authorities discovered the short-weight loaves; nevertheless, Eagleton had already obtained book credit on the strength of his misrepresentation.
- Eagleton was charged with, and convicted of, attempting to obtain money by false pretenses.

## Issues

1. Whether Eagleton’s conduct, though stopping short of receiving payment, went beyond mere preparation and constituted an attempt to obtain money by false pretenses.
2. Whether obtaining book credit through false pretenses is sufficiently connected to the completed offense where payment would occur only through subsequent administrative action.

## Decision

- The court affirmed the conviction.
- Eagleton’s acts constituted an attempt because he had performed the last acts required of him to obtain payment by deception.
- The absence of an actual cash transfer, due to discovery of the fraud, did not negate attempt liability.

## Legal Principles

- Attempt requires conduct that is more than remote preparation and is “immediately connected” with commission of the offense.
- Acts “remotely leading” toward the crime are not attempts; acts sufficiently proximate to completion may be.
- A defendant may be guilty of attempt where he has done all acts within his power necessary to complete the offense, and completion is prevented only by external intervention (including detection).
- For obtaining money by false pretenses, securing official credit on the faith of a misrepresentation can satisfy the proximity required for attempt when no further action by the defendant is needed to trigger payment.

## Conclusion

Eagleton established that attempt liability attaches when a defendant’s deceptive conduct has progressed to a proximate stage—here, obtaining parish book credit based on false pretenses—such that the defendant has completed all necessary steps on his part, even though final payment is stopped by discovery.


Regina v. Eagleton, 6 Cox C.C. 559 (Crown Cas. Res. 1855)