Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Virginia

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of possession of cocaine with intent to distribute, second offense, upon Defendant's conditional guilty plea, holding that the trial court did not err in denying Defendant's pretrial motion to suppress. At issue in this case was whether, at the time Defendant was seized by detectives, the detectives had reasonable suspicion to believe that they were about to be assaulted with a weapon. Defendant argued on appeal that the detectives seized him in violation of the reasonable suspicion standard adopted in Terry v. Ohio, 392 U.S. 1 (1968). The Supreme Court disagreed, holding that, considering the totality of the circumstances, the detectives in this case had the same practical, experience-based concern for their safety as the police officer had in Terry, and therefore, the trial court correctly denied Defendant's motion to suppress. View "Hill v. Commonwealth" on Justia Law

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The Supreme Court reversed the decision of the trial court and set aside the award of the condemnation commissioners to the Helmick Family Farm, LLC for a taking of slightly more than two acres of land along with some easements, holding that the reasonable probability of rezoning of property taken through condemnation may be relevant to the property's fair market value and that Helmick presented sufficient concrete facts to warrant submission of the question of reasonable probability of rezoning to a jury. On appeal, Helmick argued that exclusion of certain evidence prevented the commissioners from considering probative evidence concerning the fair market value of the land at issue. The Supreme Court agreed, holding (1) ample authority supports the admissibility of evidence that the property taken has a reasonable probability of rezoning; (2) nothing in prior cases forecloses the admissibility of such evidence; (3) there are certain parameters concerning such evidence; and (4) Helmick presented sufficient concrete facts to warrant submission of the question of reasonable probability of rezoning to a jury. View "Helmick Family Farm v. Commissioner of Highways" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree murder, holding that the trial court did not violate the holding of Batson v. Kentucky, 476 U.S. 79 (1986) by permitting the prosecutor to exercise a peremptory strike of an African-American juror. Defendant's counsel conceded in the trial court that the prosecutor gave a race-neutral reason for the peremptory strike. However, at a post-trial hearing, Defendant's counsel told the trial court that the prosecutor's stated reason for the strike was not supported by the transcript. On appeal, Defendant argued that the strike was racially motivated. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant's motion to set aside the verdict based upon his Batson challenge because the record provided ample support for the trial court's finding that Defendant had not met his burden of proving purposeful racial discrimination. View "Bethea v. Commonwealth" on Justia Law

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The Supreme Court affirmed Defendant's conviction for violating Va. Code 18.2-374.3(C) by using a computer for the purpose of soliciting a minor, holding that the trial court and the court of appeals did not err in concluding that the statute did not violate Defendant's freedom of speech or his due process rights under the First and Fourteenth Amendments of the United States Constitution. After the jury convicted Defendant he moved for a new trial, claiming that the statute was unconstitutionally vague in violation of the Fourteenth Amendment and overbroad in violation of the First Amendment. The trial court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that there was no merit in Defendant's vagueness or overbreadth challenges to section 18.2-374.3(C). View "Stoltz v. Commonwealth" on Justia Law

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The Supreme Court held that Respondents, who were both previously adjudicated to be sexually violent predators and were committed to the Department of Behavioral Health and Developmental Services after a trial court determined that they had violated the terms of their conditional release, were not entitled to a State-appointed psychological expert to assist them in a hearing. Respondents filed motions asking for a court-appointed psychological expert to assist them in a hearing to determine whether they violated the conditions of their release and whether those violations rendered them unsuitable for conditional release. Specifically, Respondents argued that, because they were indigent, the Due Process Clause required the appointment of an expert. The circuit courts denied the motions and determined that Respondents violated the conditions of their release. The Supreme Court affirmed, holding that given the temporary, expedited nature of the hearing and the other protections afforded Respondents, including the right to counsel, the Due Process Clause did not require the State to appoint an expert. View "Harvey v. Commonwealth" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the trial court's denial of Defendant's motion to suppress and affirming Defendant's convictions, holding that that trial court did not err in denying Defendant's motion to suppress. Defendant was convicted of first degree murder and robbery and sentenced to life imprisonment. Defendant appealed the denial of his motion to suppress evidence obtained as a result of a police interrogation, arguing that his constitutional rights under Miranda v. Arizona, 384 U.S. 436 (1966), and its progeny were denied because the interrogation took place under circumstances requiring Miranda warnings prior to questioning and that the warnings he was given were constitutionally insufficient. The court of appeals affirmed the convictions, holding that Defendant was effectively advised under Miranda. The Supreme Court affirmed, holding (1) the trial court properly found that no Miranda warnings were required; and (2) the warnings given to Defendant were a fully effective equivalent of the warnings required by Miranda. View "Spinner v. Commonwealth" on Justia Law

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The Supreme Court dismissed Petitioner's petition for writ of habeas corpus, holding that the petition was untimely under Va. Code 8.01-654(A)(2). In 1970, Petitioner was convicted of murder and sentenced to death. Petitioner was subsequently resentenced to life imprisonment. In 2016, Petitioner filed the present petition for a writ of habeas corpus, asserting that new evidence exculpated him. While acknowledging that his petition was untimely, Petitioner argued that the limitation period violated the Suspension Clause of Va. Const. Art. I, 9. The Supreme Court disagreed, holding (1) Petitioner's petition was time barred; and (2) Petitioner's inability to question and present new evidence bearing on his factual guilt or innocence did not violate the Suspension Clause. View "Brown v. Warden" on Justia Law

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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

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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

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The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the Tax Department on the Corporate Executive Board Company’s (CEB) complaint alleging that its income tax assessments violated the “dormant” Commerce Clause and the Due Process Clause of the United States Constitution and that the assessments were “inequitable” under the Tax Department’s regulations, holding that the circuit court did not err in declining to grant relief. CEB sought relief from the assessments for the years 2011, 2012, and 2013 and requested a redetermination of its income tax. The circuit court found in favor of the Tax Department. The Supreme Court affirmed, holding (1) the Tax Department’s apportionment of CEB’s income tax was in accord with constitutional requirements; and (2) the regulation allowing relief did not apply under its plain language. View "The Corporate Executive Board Co. v. Department of Taxation" on Justia Law