Justia Virginia Supreme Court Opinion Summaries

The Supreme Court upheld two capital murder convictions against Alfredo Rolando Prieto as well as convictions for rape, grand larceny, and two counts of felonious use of a firearm. The Court remanded for resentencing based on a finding of error in the penalty phase of the trial. Following a new penalty phase, the circuit court entered a final order imposing the death penalty. The Supreme Court affirmed after addressing Prieto's several assignments of error, holding that the circuit court did not err in its judgment and that there was no reason to commute or set aside the sentences of death. View "Prieto v. Commonwealth" on Justia Law

Judy Maretta, as the named beneficiary of a Federal Employees' Group Life Insurance (FEGLI) policy, received FEGLI benefits upon the death of her ex-husband. Jacqueline Hillman, the widow of the deceased, filed an action against Maretta, claiming that pursuant to Va. Code Ann. 20-111.1(D), Maretta was liable to her for the death benefits received. Maretta claimed that the state law was preempted by 5 U.S.C. 8705 and 8705 because the state statutes granted FEGLI benefits to someone other than the named beneficiary in violation of FEGLIA's terms. The circuit court concluded that section 20-111.1(D) was not preempted by FEGLIA and entered judgment against Maretta. The Supreme Court reversed and entered judgment for Maretta, holding that because Congress intended for FEGLI benefits to be paid and to belong to a designated beneficiary, FEGLIA preempts section 20-111.1(D). View "Maretta v. Hillman" on Justia Law

Mark Lahey was convicted of two counts of attempted first degree murder. The court of appeals and Supreme Court refused Lahey's petitions for appeal. Lahey subsequently filed a petition for a writ of habeas corpus. Lahey submitted his habeas petition for filing on the last day of the limitations period but did not complete payment of the filing fee until days later. The circuit court dismissed the petition as untimely under Va. Code Ann. 8.01-654(A)(2) upon determining that, under the express requirements of Va. Code Ann. 8.01-655, the petition could not be filed, or deemed filed, without proper payment of the filing fee. The Supreme Court affirmed, holding that Lahey's habeas petition was time-barred under section 8.01-654(A)(2). View "Lahey v. Johnson" on Justia Law

Jean Moreau & Associates brought this suit against the Health Center Commission for the County of Chesterfield (HCC), a municipal corporation, seeking a declaratory judgment and alleging claims for breach of contract and quantum meruit. The circuit court dismissed Jean Moreau's claims. The Supreme Court affirmed, holding (1) because Jean Moreau did not comply with the mandatory procedural requirements of the Virginia Public Procurement Act in bringing its breach of contract claim against HCC, the circuit court did not err in concluding that the claim was barred; and (2) the circuit court did not err in concluding that Jean Moreau's quantum meruit claim was barred by the doctrine of sovereign immunity for HCC's development and operation of Springdale, an independent living facility, because (i) municipal corporations performing governmental functions are immune from quantum meruit claims, (ii) HCC was not entitled to absolute immunity simply because it was created by a county and not a municipality, but (iii) Springdale served a governmental function. View "Jean Moreau & Assocs., Inc. v. Health Ctr. Comm'n" on Justia Law

In 1994, Michael Haas was convicted at a bench trial in the circuit court of sodomy committed upon his two sons in 1992 and 1993, when they were eleven and nine years of age, respectively. After Haas' petition for writ of habeas corpus was denied, Hass filed a petition for a writ of actual innocence based on non-biological evidence, including recantation evidence. The court of appeals denied Haas' request to refer the case to the circuit court for an evidentiary hearing and dismissed the petition. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in (1) declining to refer the case back to the circuit court for an evidentiary hearing, and (2) finding that Haas failed to carry his burden of proof and, accordingly, granting the Commonwealth's motion to dismiss his petition. View "Haas v. Commonwealth" on Justia Law

Pursuant to a guilty plea, Steven DeMille was convicted of rape. Before DeMille's release from incarceration, the attorney general filed a petition seeking the civil commitment of DeMille as a sexually violent predator. After a bench trial, the circuit court entered an order declaring DeMille to be a sexually violent predator. At issue on appeal was whether in a proceeding under the Civil Commitment of Sexually Violent Predators Act, the determination that the respondent is likely to engage in sexually violent acts must be based solely on expert testimony that states an opinion to that effect in express terms. The Supreme Court affirmed, holding that the factual determination of whether a respondent is a sexually violent predator likely to engage in sexually violent acts is to be based on the totality of the record, including but not limited to expert testimony. View "DeMille v. Commonwealth" on Justia Law

Following a bench trial, the circuit court found Jerrod Quarles guilty of robbery and conspiracy to commit robbery. The court of appeals reversed, holding that the circuit court erred in denying Quarles' motion to suppress where the police impermissibly reinitiated communication with Quarles after he invoked his right to counsel in violation of his rights under the Fifth Amendment, and therefore, Quarles' subsequent waiver of his Miranda rights was not voluntary. The Supreme Court reversed, holding that the circuit court did not err in denying Quarles' motion to suppress where the police officer would not have known that Quarles was likely to respond to his statement and Quarles was not particularly susceptible to exposure to such statements. View "Commonwealth v. Quarles" on Justia Law

At issue in this appeal was whether a bail bondsman licensed in another state but not in Virginia had the authority to enter Virginia and apprehend a fugitive bailee. In a bench trial, Defendant, an out-of-state bail bondsman, was convicted of attempted abduction and use of a firearm in the commission of a felony. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the General Assembly plainly manifested its intent to abrogate the common law rule allowing out-of-state bail bondsmen and bounty hunters to enter Virginia to apprehend fugitive bailees; and (2) there was sufficient evidence to establish the specific intent necessary to support a conviction of attempted abduction. View "Collins v. Commonwealth" on Justia Law

In this action, the trial court granted summary judgment against a locality, holding it liable to landowners under the State Water Control Law, Va. Code Ann. 62.1-44.2 through -44.34:28, in particular Code 62.1-44.34:18(C) of the Oil Discharge Law, for the contamination of groundwater by leachate and landfill gas. The Supreme Court reversed the trial court's judgment, holding that the trial court erred in awarding summary judgment to the landowners and finding the locality liable under the Oil Discharge Law, as the Oil Discharge Law does not apply to the passive, gradual seepage of leachate and landfill gas into groundwater. View "Campbell County v. Royal" on Justia Law

At a bench trial, the circuit court found Curtis Branham guilty of possession of cocaine with intent to distribute. The court of appeals affirmed. Branham appealed, arguing that the circuit court erred in denying his motion to suppress the Commonwealth's evidence on Fourth Amendment grounds. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Branham's motion to suppress where the arresting officer's search of Branham's person and vehicle and the results of those searches were not fruits of an unlawful seizure in violation of the Fourth Amendment; and (2) the circuit court did not err in admitting the certificate of analysis of the cocaine into evidence where the chain of custody evidence was sufficient. View "Branham v. Commonwealth" on Justia Law