Rankin v. Commonwealth (P)

After a police officer fatally shot a suspected shoplifter, the circuit court in his murder trial denied his motion in limine to exclude his statement to a witness on the scene: “It’s my second one.” The statement was admitted at trial, and the jury found the defendant guilty of voluntary manslaughter.

On appeal, the court of appeals held that the statement “did not indicate [that the defendant] had shot and killed another person,” that the statement met exceptions to the rule against propensity evidence, and that any error in admitting it was harmless.

Because the defendant failed to assign error to the court of appeals’ holding that any error was harmless, this court will uphold the ruling.


Rankin v. Commonwealth (P), No. 180812, Mar. 28, 2019. SCV (per curiam order) from CAV.

Categories: Opinions, Published, Supreme Court of Virginia

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