Commonwealth of Virginia v. James Tyler Myers

CourtCourt of Appeals of Virginia
DecidedJune 23, 2026
Docket1372253
StatusPublished

This text of Commonwealth of Virginia v. James Tyler Myers (Commonwealth of Virginia v. James Tyler Myers) 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.

Bluebook
Commonwealth of Virginia v. James Tyler Myers, (Va. Ct. App. 2026).

Opinion

COURT OF APPEALS OF VIRGINIA

Record No. 1372-25-3

COMMONWEALTH OF VIRGINIA v. JAMES TYLER MYERS

Present: Judges Malveaux, Athey and Frucci Argued at Lexington, Virginia Opinion Issued June 23, 2026

FROM THE CIRCUIT COURT OF FRANKLIN COUNTY Timothy W. Allen, Judge

Amanda L. Lavin, Assistant Attorney General (Jason S. Miyares,1 Attorney General; Theophani K. Stamos, Deputy Attorney General; Erin D. Whealton, Senior Assistant Attorney General/Chief, on briefs), for appellant.

Steven P. Milani for appellee.

PUBLISHED OPINION BY JUDGE MARY BENNETT MALVEAUX

The Commonwealth petitioned the circuit court to civilly commit James Tyler Myers as a

sexually violent predator following his conviction for carnal knowledge of a minor between 13 and

15 years of age. The circuit court denied the petition on the ground that carnal knowledge is not a

sexually violent act under the terms of the Sexually Violent Predators Act (“the Act”), Code

§§ 37.2-900 to -921. The Commonwealth appeals, arguing that the circuit court erred in its

interpretation of the Act and in holding that Myers is not a sexually violent predator as defined by

the Act. For the following reasons, we reverse the circuit court’s judgment.

1 Jay C. Jones succeeded Jason S. Miyares as Attorney General on January 17, 2026. I. BACKGROUND

“The pertinent facts are not in dispute and, pursuant to familiar principles, will be viewed

in the light most favorable” to Myers, the prevailing party below. DeMille v. Commonwealth,

283 Va. 316, 318 (2012).

In 2021, Myers entered into a plea agreement and was convicted of carnal knowledge of a

minor, in violation of Code § 18.2-63(A).2 Based on this conviction for a sexually violent

offense as defined by the Act, the Commonwealth petitioned for Myers’s civil commitment as a

sexually violent predator. Pursuant to the Act, the circuit court scheduled a hearing to determine

if there was probable cause to adjudicate Myers to be a sexually violent predator.

Prior to the hearing, Dr. Ilona Gravers, a licensed clinical psychologist, interviewed

Myers, reviewed his clinical and criminal records, and submitted a written evaluation to the

circuit court opining on whether Myers satisfied the sexually violent predator criteria.

Dr. Gravers concluded that Myers satisfied the criteria based on his conviction for a sexually

violent offense; her diagnosis of antisocial personality disorder; and her conclusion that Myers’s

disorder affected his volitional and emotional capacity, making it difficult for him to control his

predatory behavior and likely that he would engage in sexually violent behavior. Gravers opined

that Myers presented “a well above average probability of sexually violent recidivism.”

At the hearing, the circuit court found probable cause to believe that Myers was a

sexually violent predator. The circuit court then scheduled a trial on the question of Myers’s

2 At the time of the offense, Myers was 24 years old and the victim was 14 years old. Under the plea agreement, Myers also pleaded guilty to three counts of possession of child pornography, in violation of Code § 18.2-374.1:1. -2- status and potential civil commitment. It also appointed Dr. Craig S. King, a licensed clinical

psychologist, as Myers’s expert.3

Dr. King filed his written evaluation with the circuit court prior to trial. Like

Dr. Gravers, Dr. King noted Myers’s conviction for a sexually violent offense and diagnosed

Myers with antisocial personality disorder. But Dr. King was unable to opine on whether Myers,

because of his personality disorder, would find it difficult to control his predatory behavior, thus

making it likely that he would engage in sexually violent acts. Dr. King noted that his “difficulty

with answering this question is that ‘predatory behavior’ is not statutorily defined” by the Act;

“[t]herefore, I cannot determine if his actions were predatory.” Dr. King also took issue with the

Act’s classification of carnal knowledge of a minor as a sexually violent offense. Noting that

“Myers has not been charged with or convicted of a sex offense that involved violence,” he

opined that “[w]hile Carnal Knowledge is statutorily defined as a Sexually Violent Offense, with

all due respect to the SVP statute, it does not make sense to define consensual, but illegal sexual

conduct as a violent sex offense.” This was “especially [so] since Carnal Knowledge, by

definition, does not involve force or violence.” Dr. King further opined that Myers’s “offending

was minor compared to those designated as Sexually Violent Predators” and that “[c]linically,

the evidence does not support a finding that [he] is likely to commit sexually violent acts in the

future.” While Myers’s “comprehensive risk assessment indicate[d]” that he was “in a category

of sex offenders who are in the Well Above Average Risk range for committing sex offenses in

the future,” Dr. King ultimately concluded that “it is most likely, if he commits another sex

offense, that it will be a non-sexually violent offense as he does not have a pattern of committing

sexually violent acts.”

3 See Code § 37.2-907(A) (providing for appointment of “expert assistance” upon a finding of probable cause that an individual is a sexually violent predator). -3- At trial, Dr. Gravers testified and reiterated her diagnosis of Myers’s antisocial

personality disorder, which she characterized as “one of the two strongest risk factors for future

sexual offending.” She explained that because of his condition, when Myers “experiences a

sexual urge he acts on it, regardless of the consequences. So it may be consensual, it may not be

consensual. . . . He does what he wants to do when he wants to do it, really without any regard

to the effects of his behavior.” Gravers opined that Myers selected child victims because “[h]e

wanted to do what he wanted to do. Adolescents or teenagers are more easily manipulated.”

Although Myers would not “cur[e] or grow[] out of” his disorder, he could “learn how to control

it” through treatment. Dr. Gravers reiterated that because of Myers’s disorder, which “make[s] it

difficult for him to control his predatory behavior,” he was “likely . . . to commit another

sexually violent act.” During cross-examination, Dr. Gravers agreed that if Myers reoffended,

“it would probably be another carnal knowledge type of offense,” stating that she believed the

offense would “be against a teenager.” She also noted that because Myers’s “manner or MO is

manipulation,” he was unlikely to use actual force or violence in committing another sexual

offense.

Upon the conclusion of the Commonwealth’s evidence, Myers moved to strike. He

acknowledged he had been convicted of carnal knowledge of a minor and that carnal knowledge

was defined as a “sexually violent offense” by Code § 37.2-900 of the Act. But Myers observed

that the language of the carnal knowledge statute, Code § 18.2-63, specifies that the offense

occurs “without the use of force.” He also noted Dr. Gravers’s testimony that if he reoffended,

he was not likely to engage in sex offenses “that involve[] the use of actual force or violence.”

Accordingly, Myers argued, because Code § 37.2-900 defines a sexually violent predator as one

who is likely to reoffend by engaging in a “sexually violent act,” but does not define the term

“sexually violent act,” by applying the “common dictionary definition” to his predicate offense

-4- and Dr.

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