Watson-Scott v. Commonwealth (U)

In the defendant’s trial for second-degree murder, evidence was sufficient to support findings of malice and transferred intent. A rational juror could have found that when the defendant fired a deadly weapon multiple times up St. James Street he was attempting to shoot a specific person — here, a man who had been walking and talking with him just a minute before. Although the victim was not that person, she was a bystander who suffered direct and immediate harm that was within the scope of the defendant’s effort to shoot his intended target.


Watson-Scott v. Commonwealth (U), No. 1538-17-2, Dec. 4, 2018. CAV (Malveaux) from City of Richmond (Cavedo).

Categories: Court of Appeals of Virginia, Opinions, Unpublished


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