Anderson v. Commonwealth (P)

The circuit court did not err by refusing to admit the victim’s prior criminal charges and convictions into evidence at the defendant’s trial for voluntary manslaughter.

The excluded charges and convictions occurred 17 to 20 years earlier and didn’t establish that the victim had previously behaved in a violent manner. The defendant failed to call a witness to testify about the underlying conduct or to otherwise establish the foundation of the charges at issue. The excluded charges and convictions were also somewhat cumulative of other trial evidence as to the victim’s propensity for violence.


Anderson v. Commonwealth (P), No. 1228-17-1, Nov. 6, 2018. CAV (Chafin) from Va. Beach (Lilley).

Categories: Court of Appeals of Virginia, Opinions, Published

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