Justia Virginia Supreme Court Opinion Summaries

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 dismissed Appellant's appeal challenging a just compensation award, holding that the notice of appeal was not timely filed.In this condemnation proceeding, Appellant appealed from an order distributing funds held by the circuit court. The Town of Culpeper filed a motion to dismiss the appeal as untimely. The Supreme Court granted the motion to dismiss, holding (1) an order confirming the jury's award of just compensation is a final order for purposes of appeal in a condemnation proceeding; and (2) Appellant's notice of appeal was untimely under Rule 5:9(a). View "Dwyer v. Town of Culpeper" on Justia Law

The Supreme Court affirmed the decision of the circuit court dismissing on demurrer Plaintiff’s complaint filed under 42 U.S.C. 1983 claiming that prison officials had violated his due process rights during a prison disciplinary proceeding that resulted in a $10 fine, holding that there was no violation of Plaintiff’s due process rights.Plaintiff, an inmate in a Virginia prison, filed this action against several prison officials alleging deprivations of his due process rights. The circuit court granted Defendants’ demurrer, finding that the disciplinary proceeding had not deprived Plaintiff of any due process rights and that all of the defendants were entitled to qualified immunity. The Supreme Court affirmed, holding that the circuit court did not err in holding that Plaintiff’s allegations did not state a viable due process claim. View "Anderson v. Warden" 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 judgment of the circuit court granting Defendant’s motion to dismiss for lack of personal jurisdiction, holding that the facts did not establish personal jurisdiction under the basis presented to the court, the “persistent course of conduct” clause of Virginia’s long arm statute, Va. Code 8.01-328.1(A)(4).Plaintiff filed a complaint in the Circuit Court of Loudoun County against Defendant, alleging that Defendant had illegal used asserts from accounts belonging to others to fund certain litigation. Defendant filed a motion to dismiss for lack of personal jurisdiction by special appearance. The circuit court indicated that section 8.01-328.1(A)(4) constituted the only viable ground for personal jurisdiction over Defendant and that the facts did not support a finding that Defendant engaged in a “persistent course of conduct” in Virginia. The Supreme Court affirmed, holding that the circuit court did not err in ruling that Defendant did not engage in a persistent course of conduct in the forum jurisdiction and was not therefore subject to the circuit court’s in personam jurisdiction. View "Mercer v. MacKinnon" on Justia Law

The Supreme Court reversed the decision of the circuit court denying Defendant’s motion to compel arbitration, holding that the circuit court erred in denying the motion for arbitration because the parties’ disagreements were controversies arising out of or relating to their contract, and therefore, pursuant to the contract, an arbitrator must resolve them.Plaintiffs sued Defendant, alleging that the home Defendant constructed for Plaintiffs suffered from defects that caused damage to the home. Defendant filed a motion to compel arbitration under the arbitration clause of the parties’ contract. The circuit court denied the motion, concluding that the arbitration clause was unenforceable. The supreme Court reversed, holding that the parties’ disagreement over the interpretation of the arbitration clause, as well as the application of the doctrine of impossibility to the arbitration clause, were “controvers[ies] arising out of or relating to the contract,” and therefore, the circuit court erred in refusing to compel arbitration. View "Brush Arbor Home Construction, LLC v. Alexander" 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