This document discusses the legal development of the concept of appropriation as it relates to theft. It summarizes several key court cases between 1971 and 1993 that helped define when appropriation occurs. The cases established that appropriation can take place before an item is removed from the store if the person's actions are inconsistent with the owner's rights, such as switching price tags or loading goods with the intent to steal them and divert them from their destination. Appropriation requires an act that assumes the rights of ownership over an item.