Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of voluntary manslaughter, holding that the trial court did not abuse its discretion when it permitted the admission of Defendant's statement, "It's my second one," which was made to a witness immediately following the shooting of the victim.The court of appeals held that any error in admitting evidence of the statement was harmless because Defendant had a fair trial on the merits and that substantial justice was reached. The Supreme Court held that because Defendant failed to assign error to the appellate court's holding that any error was harmless, the court of appeals judgment is affirmed. View "Rankin v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction after the trial court had denied Defendant's motion to suppress, holding that the exclusionary rule did not apply under the facts of this case.Defendant was convicted of stolen property. At issue on appeal was whether the trial court should have excluded evidence obtained by police officers during a warrantless search of a motorcycle parked on a private residential driveway. The case made its way to the United States Supreme Court, which held that the automobile exception to the Fourth Amendment does not permit a police officer to enter the curtilage of a home without a warrant in order to search a vehicle parked on that curtilage. The Supreme Court left for resolution on remand whether the warrantless intrusion on Defendant's house may have been reasonable on a different basis. On remand, the Supreme Court affirmed the trial court's denial of Defendant's motion to suppress, holding that the good faith exception to the exclusionary rule applied because, at the time of the search, a reasonably well-trained police officer would not have known that the automobile exception did not permit him to search a motorcycle located a few feet across the curtilage boundary of a private driveway. View "Collins v. Commonwealth" on Justia Law

The Supreme Court granted Petitioner’s petition for a writ of actual innocence based on biological evidence pursuant to Va. Code 19.2-327.2 et seq. and vacated Petitioner’s conviction, holding that the totality of the evidence led to the conclusion that the writ of actual innocence must be issued.Petitioner was convicted of rape, carnal knowledge, and burglary. Years later, after Petitioner received Department of Forensic Science test results eliminating him as a contributor of a semen stain found on the jeans worn by the victim, Petitioner filed a petition for writ of actual innocence in the Supreme Court. The Court granted the petition, holding that the totality of the evidence showed that Petitioner proved, by clear and convincing evidence, all of the allegations required under section 19.2-327.3(A) and that no rational trier of fact would have found Petitioner guilty beyond reasonable doubt where Petitioner had been scientifically proven by DNA analysis not to be the source of the sperm found on the victim’s jeans or the male DNA found on the vaginal swab obtained from the victim. View "In re Scott" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the circuit court sentencing Defendant, as to his five cocaine distribution offenses, to an active sentence equal to the mandatory minimum sentence of three years’ imprisonment on each offense under Va. Code 18.2-248(C), holding that the circuit court did not err in rejecting Defendant’s request for application of the so-called “safety valve” provision as to his convictions on these offenses.On appeal, Defendant argued that the court of appeals erred in upholding the circuit court’s ruling that Defendant did not qualify under the safety valve provision of section 18.2-248(C) for exemption from the three-years mandatory minimum sentences on four of his five cocaine distribution offenses. The Supreme Court affirmed, holding that the safety valve provision of the statute did not apply to Defendant’s case. View "Stone v. Commonwealth" on Justia Law

The Supreme Court reversed the decision of the trial court denying an information for the forfeiture of a vehicle used by Defendant during a sale of illegal drugs, holding that the trial court incorrectly interpreted Va. Code 19.2-386.22(A), the applicable civil forfeiture statute.Specifically, the trial court held that section 19.2-386.22(A) does not authorize the forfeiture of property used in a single episode of illegal drug distribution, and therefore, Defendant’s one-time use of his pickup truck to sell illegal drugs did not render it subject to civil forfeiture. The Supreme Court disagreed, holding (1) civil forfeiture under section 19.2-386.22(A) does not require a certain number of uses but instead requires that the vehicle be used in substantial connection with illegal drug activity; and (2) the undisputed facts proved by clear and convincing evidence that Defendant used the pickup truck in substantial connection with the illegal distribution of a controlled substance. View "Commonwealth v. Hall" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the circuit court denying Defendant’s motion for continuance pursuant to Va. Code 19.2-159.1, holding that there was no reversible error in the court of appeals’ judgment.Defendant pled guilty to a single charge of robbery. At a sentencing hearing, Defendant sought and was granted a continuance to July 15. On July 14, Defendant filed a motion to substitute counsel and also sought a continuance pursuant to section 19.2-159.1. The circuit court declined to substitute counsel and denied the motion for continuance. The court of appeals affirmed, ruling that Defendant failed to demonstrate exceptional circumstances to obtain a last-minute continuance. On appeal, Defendant asserted that section 19.2-159.1 required him to obtain private counsel, which he had done, and that he was therefore entitled to a continuance. The Supreme Court disagreed, holding that the statute confers no rights on defendants, and therefore, defendants are entitled to no remedy if a court declines to substitute counsel and grant a continuance for counsel to prepare. View "Reyes v. Commonwealth" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant’s petition for writ of actual innocence based on nonbiological evidence, holding that the court of appeal abused its discretion in refusing to order an evidentiary hearing before denying the petition.The petition in this case and its supporting evidence raised substantial factual questions. The court of appeals resolved those questions on the record without referring any issues to a circuit court for an evidentiary hearing, holding that Appellant failed to demonstrate that the evidence upon which he relied was material. The Supreme Court reversed, holding that the court of appeals abused its discretion by determining that the facts in this case did not require further development in a circuit court evidentiary hearing. View "Dennis v. Commonwealth" on Justia Law

The Supreme Court reversed the trial court’s determination that Defendant’s motion filed pursuant to the safety value provision of Va. Code 18.2-248(C), which provides potential relief from mandatory minimum sentences according to certain terms, was untimely and declining to rule on the merits, holding that the motion was timely and warranted consideration on the merits.The safety value provision provides for relief from mandatory sentences when the defendant truthfully provides all information and evidence concerning his offense to the Commonwealth not later than the time of the sentencing hearing. In this case, Defendant provided the required information concerning his offense immediately prior to the sentencing hearing. The trial court denied the motion, and Defendant received the mandatory sentences. The Supreme Court reversed, holding that disclosure was timely made to the Commonwealth, and therefore, the motion warranted consideration on the merits for the completeness and truthfulness of the disclosure as well as any further disclosure made to the Commonwealth before resentencing. View "Hall v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the Court of Appeals sustaining Defendant’s conviction for voluntary manslaughter, holding that the Court of Appeals did not err when it found the evidence was sufficient to uphold the conviction.A jury found Defendant guilty of voluntary manslaughter. Defendant filed a motion to set aside the jury’s verdict based on insufficient evidence to prove the elements of the offense of voluntary manslaughter. The trial court denied the motion, finding that there was sufficient evidence to support the jury’s verdict. The Court of Appeals affirmed. The Supreme Court affirmed, holding that the Court of Appeals did not err in affirming Appellant’s conviction of voluntary manslaughter because the evidence was sufficient to support the conviction. View "Smith v. Commonwealth" on Justia Law

The Supreme Court reversed the judgment of the Court of Appeals affirming Defendant’s convictions on three counts of violating Va. Code 18.2-181 without reviewing the merits of his assignment of error and reinstated the judgment of the circuit court, holding that the circuit court’s determination of Defendant’s guilt was not plainly wrong or without support in the evidence.The Court of Appeals affirmed Defendant’s convictions on three counts of larceny by worthless check without reaching the merits of his assignment of error challenging the sufficiency of the evidence to support his conviction. The Court of Appeals held that Defendant’s assignment of error was not preserved for appeal in the circuit court under the requirements of Rule 5A.18. The Supreme Court vacated the opinion of the Court of Appeals and reinstated the judgment of the circuit court, holding (1) this Court assumes, without deciding, the the circuit court’s ruling on the motion to vacate Defendant’s convictions was properly before the Court of Appeals; and (2) the evidence was sufficient as a matter of law to support Defendant’s convictions. View "McGinnis v. Commonwealth" on Justia Law