Archer v. Fink

56 Va. Cir. 253, 2001 Va. Cir. LEXIS 455
CourtCharlottesville County Circuit Court
DecidedJuly 13, 2001
DocketCase No. (Law) 98-188
StatusPublished

This text of 56 Va. Cir. 253 (Archer v. Fink) is published on Counsel Stack Legal Research, covering Charlottesville County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Archer v. Fink, 56 Va. Cir. 253, 2001 Va. Cir. LEXIS 455 (Va. Super. Ct. 2001).

Opinion

By Judge Edward L. Hogshire

This letter opinion addresses the issues presented in several pre-trial motions filed by the parties in the above-styled action set for trial on August 2 and 3, 2001. Plaintiffs Motions in limine, Defendant’s Motions in limine,1 and Plaintiffs Motion to Grant Partial Summary Judgment are all resolved herein. Upon consideration of the arguments advanced at the May 24, 2001, hearing and briefs submitted to the Court, the Motions in limine are denied in part and granted in part, the Motion to Grant Partial Summary Judgment is denied, and judgment on the Motion to Strike Defense is withheld until the conclusion of evidence.

[254]*254I. Plaintiff’s Motions in Limine

A. Testimony of the Magistrate and Defendant

Plaintiff asked that this Court prohibit the defendant from testifying about his statements to the magistrate when the warrant was issued. Plaintiff bases this request on Virginia Code § 19.2-271 which reads in pertinent part, “No. .. magistrate . .. shall be competent to testify in any ... civil proceeding ... as to any matter which came before him in the course of his official duties.” Plaintiff urges that this prohibition disallows the testimony of the magistrate concerning the issuance of the warrant and in turn denies Plaintiff the opportunity to impeach Defendant’s testimony concerning that issuance.-Defendant counters that impeachment is not an absolute right and that the testimony can be impeached through other methods. Upon due consideration, this Court will permit Defendant’s testimony, subject to hearsay and relevancy objections. The Motion in limine is therefore granted in part and denied in part.

Plaintiff also asked this Court to allow the magistrate who issued the instant warrant to testify about the general facts surrounding the office of magistrate and her qualifications. In addition, the Defendant, who has no objection to the testimony, desires to use the fact that the magistrate has a law degree and ample experience in her position in two ways. (1) Based on the arguments in Defendant’s Response to Plaintiff’s Motion in limine, Defendant desires to use the Magistrate’s law degree as a basis for an advice of counsel defense. Since this defense has not been pleaded, it will not be considered. (2) The Magistrate’s law degree and experience might bolster the reasonableness of Defendant’s actions by lending not only her magistrate skills but also her legal training to the issuance of the arrest warrant. Virginia Code § 19.2-271 allows such testimony because it does not concern a matter which came before her in the course of her official duties. The only applicable authority which construes the meaning of the prohibition, Carter v. Commonwealth, also lends support for admitting the testimony: “Code § 19.2-271 is not a blanket prohibition against clerks testifying; it prohibits, instead, clerks testifying regarding factual matters which have come before them in the course of their official duties.” 12 Va. App. 156, 158-59 (1991). Thus, the Magistrate’s testimony about her general qualifications and duties does not violate Virginia Code § 19.2-271.

Even though this testimony is theoretically admissible, it appears to be irrelevant to the issue at hand. No more weight can be placed upon the validity of a Magistrate’s probable cause determination because he or she attended law [255]*255school or has extensive experience in the position. Virginia Code § 19.2-38.1 enumerates the training standards and prerequisites of magistrates which, once, fulfilled, equip the individual with the skills needed to issue arrest warrants. The Defendant is not entitled to place more reliance on the warrants of one magistrate over those of another because of additional education or job experience. Nor is the jury. Thus, absent further showing of relevance, the Court denies Plaintiff’s Motion in limine and will exclude testimony of the magistrate.

B. Testimony of Deputy Sheriff Chan Gianniny

Albemarle County Deputy Sheriff Chan Gianniny is expected to testify that she told the defendant hours before the arrest on October 20, 1997, that she had a recent incident in which she charged a man with driving a moped on a suspended license and he was convicted of this in General District Court in July 1997. This testimony would be used to establish Defendant’s reasonable belief in the existence of probable cause to effect the arrest warrant.

Plaintiff asks this Court to exclude Gianniny’s additional testimony that the conviction was affirmed in May 1998 by the Albemarle County Circuit Court because it is irrelevant. Plaintiff urges that Gianniny’s testimony should be limited to knowledge which she shared with Defendant on October 20, 1997. Conversely, Defendant asks this Court to admit Gianniny’s additional testimony because it is relevant to the reasonableness of Defendant’s actions. Essentially, Defendant argues that the fact that two judges ruled that driving a moped with a suspended license is a crime in Virginia demonstrates that Defendant acted reasonably and without malice.

The facts and circumstances known to the Defendant on October 20, 1997, can only include events which occurred on or before October 20,1997. Appellate affirmation occurring after October 20, 1997, is therefore irrelevant to the good faith of the Defendant when seeking this arrest warrant. The Motion in limine is granted.

C. Statutory Provisions

Plaintiff asks that this Court take judicial notice of three Virginia Code sections and summaries of them. Neither party has objection to these statutes coming before the jury. However, Defendant objects to Plaintiffs summarization of these statutes, based on interpretation rather than interpretative error. The Court will take judicial notice of the entire language [256]*256of Virginia Code §§ 46.2-301,46.2-100, and 18.2-272 but not the proffered summaries. The Motion in limine is therefore granted in part and denied in part.

D. Loss of License

Defendant is anticipated to testify that Plaintiff lost his license prior to October 20, 1997, for driving under the influence, possession of marijuana, and/or speeding 113 m.p.h. Plaintiff moves this Court to exclude this testimony because it is irrelevant to this case and/or its probative value is outweighed by its prejudicial effect.

Although Defendant stipulates that the speeding is not relevant to this cause of action, he maintains that the driving under the influence and possession charges are relevant. Defendant argues that because the Plaintiff’s license was suspended for “serious” rather than “run-of-the-mill” reasons, it helps to justify Defendant’s actions on October 20, 1997. As an example of a “run of the mill” reason, Defendant points to failure to pay fines.

The seriousness of these prior offenses could reasonably be believed to create in Defendant a sense of urgency to apprehend the Plaintiff. This desire to keep the streets safe from Plaintiff and his moped may have fueled the midnight arrest. “Evidence is relevant in the trial of a case if it has any tendency to establish a fact which is properly at issue.” Wise v. Commonwealth, 6 Va. App. 178, 187 (1988). Because the state of mind of the Defendant is at issue in this case, the Court finds that this testimony is relevant.

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Wise v. Commonwealth
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Bluebook (online)
56 Va. Cir. 253, 2001 Va. Cir. LEXIS 455, Counsel Stack Legal Research, https://law.counselstack.com/opinion/archer-v-fink-vacccharlottesv-2001.