Commonwealth of Virginia v. Christian Jason Rowe

CourtCourt of Appeals of Virginia
DecidedJanuary 30, 2024
Docket1528232
StatusUnpublished

This text of Commonwealth of Virginia v. Christian Jason Rowe (Commonwealth of Virginia v. Christian Jason Rowe) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Commonwealth of Virginia v. Christian Jason Rowe, (Va. Ct. App. 2024).

Opinion

COURT OF APPEALS OF VIRGINIA UNPUBLISHED

Present: Chief Judge Decker, Judges Beales and Lorish Argued by videoconference

COMMONWEALTH OF VIRGINIA MEMORANDUM OPINION* BY v. Record No. 1528-23-2 CHIEF JUDGE MARLA GRAFF DECKER JANUARY 30, 2024 CHRISTIAN JASON ROWE

FROM THE CIRCUIT COURT OF CHESTERFIELD COUNTY David E. Johnson, Judge

Justin B. Hill, Assistant Attorney General (Jason S. Miyares, Attorney General, on briefs), for appellant.

Steven D. Benjamin; Betty Layne DesPortes (Benjamin & DesPortes, P.C., on brief), for appellee.

Christian Jason Rowe was indicted for possession of more than five pounds of marijuana

with the intent to distribute and simultaneous possession of a firearm. See Code

§§ 18.2-248.1(a)(3), -308.4(C). Rowe filed a pretrial motion to suppress evidence, which he

alleged was obtained as the result of an unlawful entry into his home. After a hearing, the circuit

court granted the motion and suppressed the evidence. Pursuant to Code §§ 19.2-398 and -400,

the Commonwealth appeals that ruling. The appellee cross-appeals.

The Commonwealth argues that the discovery of the evidence was permissible under the

Fourth Amendment to the United States Constitution because, although the police did not have

an arrest warrant, they had a capias for Rowe’s detention that was the functional equivalent of an

arrest warrant and permitted them to enter his residence. The Commonwealth contends in the

* This opinion is not designated for publication. See Code § 17.1-413(A). alternative that the good-faith exception to the exclusionary rule applies. For the reasons that

follow, we affirm the judgment of the circuit court.

BACKGROUND1

As part of an investigation of a 2020 homicide, police identified Rowe, a

nineteen-year-old, as a suspect. Detectives Lynn Gleason and Brian Waggoner with the

Chesterfield County Police Department worked together to prepare “the documents needed” to

obtain a capias to take Rowe into custody. After those documents were submitted, a petition was

filed in the county juvenile and domestic relations district court for a capias against Rowe. The

petition did not contain Waggoner’s signature, nor was anything attached to the petition.

Instead, an intake officer signed the petition “for Detective Brian Waggoner.” The same intake

officer issued a capias to take Rowe into custody for second-degree murder and use of a firearm

in the commission of a felony.

On July 26, 2022, the Chesterfield County Police Department and U.S. Marshals Task

Force executed the capias at Rowe’s home. Detectives Waggoner, Joseph Partin, Jeff Whitlock,

and N. Crowe of the Chesterfield County Police Department participated in executing the capias

and the subsequent search warrant.

Before law enforcement arrived at Rowe’s home to execute the capias, Detective

Whitlock watched the house for thirty to sixty minutes. After the other officers arrived,

1 On review of a ruling on a motion to suppress, an appellate court “consider[s] the facts in the light most favorable to . . . the prevailing party” below, in this case, Rowe. Jones v. Commonwealth, 279 Va. 521, 527-28 (2010) (quoting Malbrough v. Commonwealth, 275 Va. 163, 168 (2008)). “We are bound by the [circuit] court’s factual findings unless those findings are plainly wrong or unsupported by the evidence.” Id. at 528 (quoting Malbrough, 275 Va. at 168); see McGee v. Commonwealth, 25 Va. App. 193, 198 (1997) (en banc). To the extent that the circuit court did not make express findings of fact, we view the evidence and the inferences deducible from it in the light most favorable to the defendant, who prevailed below. See Satchell v. Commonwealth, 20 Va. App. 641, 648 (1995) (en banc); see also Brooks v. Commonwealth, 282 Va. 90, 95 (2011) (interpreting the record in favor of the Commonwealth, the prevailing party at trial). -2- Detective Partin knocked on the door and announced himself loudly several times. Partin waited

about four minutes, but no one answered the door. Consequently, officers breached the front

door. After they entered the house, they found Rowe, who was normally in a wheelchair,

upstairs on the floor. They then took him into custody.

To make sure no one else was in the home, law enforcement conducted a protective

sweep of the house itself. While conducting the sweep, Detective Partin saw marijuana in a

bedroom closet.

Based on Partin’s observation, Detective Crowe obtained a search warrant for the house.

While executing the warrant, detectives found almost eight pounds of marijuana and a handgun.

In his motion to suppress the marijuana and the firearm, Rowe argued, in relevant part,

that the law enforcement officers unconstitutionally entered the house because they did not have

an arrest warrant. The prosecutor responded that the capias was issued based on probable cause

and met the constitutional standard for arrest warrants. She alternatively suggested that the

good-faith exception to the exclusionary rule applied.

The circuit court took the case under advisement and later issued a written decision.

Citing Payton v. New York, 445 U.S. 573 (1980), the court held that the capias was not an arrest

warrant or its equivalent and, accordingly, that the entry was presumptively unreasonable. It

held that no exigent circumstances existed justifying the forced entry. As a result, the court

applied the exclusionary rule and granted the motion to suppress. The case is now before this

Court on appeal.

ANALYSIS

On appeal of a ruling granting a defendant’s motion to suppress, the Commonwealth has

the burden to show that the circuit court’s ruling constituted reversible error. See Cole v.

Commonwealth, 294 Va. 342, 354 (2017); Commonwealth v. Benjamin, 28 Va. App. 548, 552-54

-3- (1998) (en banc). A Fourth Amendment challenge presents a mixed question of law and fact,

and we review “the [circuit] court’s application of the law de novo.” Hicks v. Commonwealth,

281 Va. 353, 359 (2011) (quoting Whitehead v. Commonwealth, 278 Va. 300, 307 (2009)).

Although a reviewing court “give[s] deference to the factual findings of the circuit court, . . . we

independently determine whether the manner in which the evidence was obtained meets the

requirements of the Fourth Amendment.” See McCain v. Commonwealth, 275 Va. 546, 552

(2008).

It is well established that “[t]he Fourth Amendment prohibits unreasonable searches and

seizures.” Collins v. Commonwealth, 297 Va. 207, 212 (2019). And warrantless searches and

seizures are “presumptively unreasonable.” See Williams v. Commonwealth, 49 Va. App. 439,

447 (2007). The circuit court held that the entry into Rowe’s home was unreasonable because it

was not supported by a warrant or exigent circumstances. This ruling forms the basis of the

present appeal.

I. Capias

The Commonwealth first argues that the capias essentially constituted a valid arrest

warrant because it is the legal and functional equivalent for constitutional purposes.

To address this argument, we begin with the state law relevant to the capias issued in this

case. The Virginia Code provides certain procedures for prosecuting crimes committed by

minors. “Proceedings in cases of adults under the age of 21 who are alleged to have committed,

before attaining the age of 18, an offense that would be a crime if committed by an adult shall be

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