Justia Virginia Supreme Court Opinion Summaries

In this case, Andrew Schmuhl ("Schmuhl") appealed the denial of his petition for a writ of habeas corpus. At his trial, Schmuhl had claimed he was involuntarily intoxicated due to prescription medications at the time of committing a home invasion, which resulted in several criminal charges. His trial counsel argued that Schmuhl's involuntary intoxication was a separate defense from an insanity defense, which they chose not to raise. However, the trial court ruled that without an insanity defense, Schmuhl could not present expert testimony about his mental state, effectively barring his involuntary intoxication defense. Schmuhl was found guilty on all counts. Schmuhl later filed a habeas corpus petition arguing that his trial counsel was ineffective due to misunderstanding the law regarding the admissibility of mental state evidence without an insanity defense. The habeas court ruled that trial counsel's performance was not deficient and that Schmuhl was not prejudiced by their performance. On appeal, the Supreme Court of Virginia affirmed the habeas court's decision, finding that Schmuhl's trial counsel's performance was objectively reasonable given the unclear state of the law at the time. The court noted that had trial counsel’s arguments been successful, they would have carried significant strategic benefits for Schmuhl, and that trial counsel's unsuccessful attempt to extend existing law for their client's benefit was not deficient. View "Schmuhl v. Clarke" on Justia Law

In this case, the Supreme Court of Virginia was asked to interpret Code § 19.2-306.1, a statute enacted in 2021 that addresses the range of punishment a court may impose upon the revocation of a suspended sentence. The defendant, Emily Katherine Delaune, was convicted of three drug offenses in 2019 and was sentenced to six years of incarceration, with four years suspended. After her release, she violated the terms of her probation by using drugs and absconding from supervision. The Circuit Court of the City of Virginia Beach revoked Delaune's suspended sentence based on these violations and ordered her to serve 60 days of active incarceration.Delaune appealed to the Court of Appeals of Virginia, arguing that under Code § 19.2-306.1, the circuit court was prohibited from imposing more than 14 days of active incarceration based on her technical violations. The Attorney General asserted that Code § 19.2-306.1 did not retroactively apply to Delaune’s probation violations.The Supreme Court of Virginia agreed with the Court of Appeals' ruling that the parties had implicitly agreed to proceed under Code § 19.2-306.1 during the probation revocation hearing, and that the Attorney General was bound by this agreement. The Supreme Court of Virginia also agreed with the Court of Appeals' interpretation of Code § 19.2-306.1, stating that the circuit court could not impose a term of active incarceration based on Delaune’s drug use, which constituted a first technical violation under the statute, and could impose a maximum of 14 days of active incarceration for Delaune’s absconding violation, which was automatically classified as a second technical violation under the statute. The Supreme Court of Virginia affirmed the judgment of the Court of Appeals, holding that the circuit court erred when it ordered Delaune to serve 60 days of active incarceration. View "Commonwealth v. Delaune" on Justia Law

The Supreme Court reversed the opinion of the court of appeals reversing Defendant's sentence for malicious wounding, holding that the court of appeals erred by reversing the trial court's restitution order as violative of Va. Code 19.2-305.1.Defendant was convicted of the malicious wounding of Justin Hawks. As a condition of Defendant's probation and suspended sentence the trial court ordered Defendant to reimburse the Virginia Department of Medical Assistance Services (DMAS) for Hawks's medical expenses. The court of appeals reversed the restitution award to DMAS and remanded the case. The Supreme Court reversed, holding that section 19.2-305.1 authorized the trial court to order restitution as a condition of Defendant's probation and sentence and to order payment of that restitution to DMAS for the portion of the medical expenses incurred by Hawks that DMAS had paid. View "Commonwealth v. Puckett" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions of three counts of aggravated sexual battery by a parent under Va. Code 18.2-67.3 and four counts of taking indecent liberties with a child under Va. Code 18.2-370.1 but vacated the portion of the court of appeals' opinion deciding that Laurie Lee's proffered testimony provided Defendant with an alibi, holding that the court erred in part.In affirming Defendant's convictions the court of appeals defined alibi as a defense based on the physical impossibility of committing a crime and held that Lee's proffered testimony served as an alibi because it placed Defendant outside of the room where the offenses occurred. The Supreme Court vacated the portion of the opinion deciding that the proffered testimony provided Defendant with an alibi but affirmed the otherwise affirmed, holding that the court of appeals erred in ruling on the merits of this case because Defendant waived his challenge that the proffered testimony was offered for impeachment. View "Moison v. Commonwealth" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction, after a jury trial, of possession of cocaine with the intent to distribute, third or subsequent offense, and possession of heroin and Furanylfentanyl with the intent to distribute, third or subsequent offense, holding that Rule 3A:15 does not preclude a trial court from timely reconsidering a motion to strike.At issue in this appeal was whether Rule 3A:15 or the Double Jeopardy Clause restricts a trial court's authority to reconsider a motion to strike that the trial court granted in error. The court of appeals concluded that, once a court grants a motion to strike, the court is foreclosed from reconsidering its decision under Rule 3A:15, which requires the court to enter an order of acquittal. The Supreme Court reversed, holding (1) Rule 3A:15 does not prevent a court from reconsidering its ruling on a motion to strike; and (2) the Double Jeopardy Clause restricts a court's authority to reconsider a motion to strike, but those limitations were not implicated in this case. View "Commonwealth v. McBride" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for a writ of habeas corpus claiming that the Virginia Department of Corrections (VDOC) failed timely to release him from prison because it under-calculated his earned sentence credits (ESCs), holding that the circuit court did not err.In his habeas corpus petition, Appellant argued that he was entitled to enhanced ESCs under the General Assembly's 2020 amendments to Va. Code 53-1-202.3 as set forth in House Bill 5148 (HB 5148). The circuit court denied the petition, concluding that Appellant was not entitled to immediate release because he was precluded from earning enhanced ESCs for time served prior to July 1, 2022. The Supreme Court affirmed, holding that Appellant was not eligible to receive enhanced ESCs under HB 5148. View "Anderson v. Clarke" on Justia Law

The Supreme Court granted Petitioner's petition seeking a writ of habeas corpus and issued the writ directed to the Director of the Virginia Department of Corrections ordering that Petitioner be released from custody, holding that Petitioner was entitled to relief on his claim that he was wrongfully denied earned sentence credits on his convictions for attempted murder that, if awarded, would result in his immediate release from incarceration.In his habeas corpus petition, Petitioner argued that he was wrongfully denied earned sentence credits on his convictions for attempted aggravated murder. Specifically, Petitioner argued that the Virginia Department of Corrections misinterpreted Va. Code 53.1-202.3(A) and, as a result, miscalculated his release date. The Supreme Court agreed, granted Petitioner's petition, and ordered that Petitioner be released from custody, holding that Petitioner established that he was entitled to relief. View "Prease v. Clarke" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of abuse or neglect of an incapacitated adult causing serious injury, holding that the trial court, sitting as fact-finder, rationally determined that Defendant's abuse and neglect of her mother caused the mother to suffer a "serious bodily injury" under Va. Code 18.2-369(B).Defendant's mother required emergency medical care and hospitalization after lying in a squalid condition on the floor of her apartment for at least two days. The Commonwealth charged Defendant under section 18.2-369(B) and, after a trial, the court found Defendant guilty of the abuse or neglect of an incapacitated adult causing serious injury. On appeal, Defendant argued that no rational fact-finder could conclude that her mother's bedsores constituted "serious bodily injury" under section 18.2-369(B)-(C). The Supreme Court disagreed and affirmed, holding that a rational trier of fact could have found beyond a reasonable doubt that Defendant's mother suffered a "serious bodily injury" under section 18.2-369(C). View "Tomlin v. Commonwealth" on Justia Law

In this criminal case, the Supreme Court held that the Due Process Clause of the United States Constitution does not require a court to pre-screen eyewitness identification testimony before the eyewitness can be permitted to make an identification of the defendant for the first time in open court.Defendant was indicted on four counts of robbery and four counts of use of a firearm in the commission of a felony for robbing a bank. After a jury trial, Defendant was convicted and sentenced to forty-five years' imprisonment. The Supreme Court affirmed, holding (1) due process did not compel the circuit court to pre-screen the identification at issue when that identification was made for the first time in court; (2) the circuit court did not abuse its discretion in ruling that Defendant's identification was more probative than prejudicial; and (3) Defendant was properly convicted of a second or subsequent offense of use of a firearm in the commission of a felony. View "Walker v. Commonwealth" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Appellant's petition for an expungement under Va. Code 19.2-392.2, holding that, in light of this Court's clarification of the standard that applies to the review of expungement petitions when the claim is that the original charge was "otherwise dismissed," remand was appropriate.Appellant was arrested on the charge of accessory after the fact of homicide and pleaded guilty to obstruction of justice, an amended charge. Appellant later filed a petition for expungement, arguing that the accessory after the fact of homicide charge qualified for expungement because it was "otherwise dismissed." The circuit court denied the petition on the grounds that the original charge that was later amended was not "completely separate and unrelated." The Supreme Court reversed, holding that where the circuit court did not rely on a Blockburger comparison of the elements to deny the expungement petition, remand was necessary. View "Williams v. Commonwealth" on Justia Law