Commonwealth v. Broce

92 Va. Cir. 412, 2016 Va. Cir. LEXIS 82
CourtAugusta County Circuit Court
DecidedJune 6, 2016
DocketCase Nos. CR16000014-00 (00-01) and CR16000024-00
StatusPublished

This text of 92 Va. Cir. 412 (Commonwealth v. Broce) is published on Counsel Stack Legal Research, covering Augusta County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Broce, 92 Va. Cir. 412, 2016 Va. Cir. LEXIS 82 (Va. Super. Ct. 2016).

Opinion

By

Judge Victor V. Ludwig

On May 26, 2016, the defendant, Douglas C. Broce, filed a Motion To Unseal Juror Questionnaires (the Motion), asking that the Court issue an order requiring the Clerk of this Court to “disclose the juror questionnaires and the responses to those questionnaires of the 2016 juror list.”1 Broce’s concern is that some felons might have been excluded from service on his jury pool. In light of the fact that these cases are scheduled for a jury trial on June 10,2016 (but seven working days from the first day on which I can deliver this decision), I thought it best to respond as soon as I could. I deny the Motion.

The basis for the Motion is the executive order (the Order) issued by the Honorable Terence R. McAuliffe, Governor of the Commonwealth of Virginia, on April 22, 2016. Order for the Restoration of Rights (April 22, 2016). Time does not permit me fully to address the issue of the constitutionality of the Order, although, given the sweeping language of Article V, Section 12, of the Constitution of Virginia, I do not see much limitation on the Governor’s power. Nevertheless, I have some doubt. However, given the constraints of time, I will leave to the General Assembly a more thorough examination of that issue in the case currently pending in [413]*413the Supreme Court of Virginia. Howell v. McAuliffe, Record No. 160784 (Va. filed May 23, 2016).

For the purposes of the case before me, I will assume that the Governor is acting within his constitutional authority. Still, the Order is not as clear as one might hope; so, considerations of constitutionality aside, its effect, application, and implementation are questionable. For example, it is difficult to discern to whom the Order applies or when it applies. It is limited to those who, as of its effective date, have “completed their sentences of incarceration” and “completed their sentences of supervised release, including probation and parole.” A Court may sentence a defendant to a term certain (e.g., 10 years), suspend a portion of that term (e.g., 1 years) for a specified period after release from incarceration (e.g., 15 years), and put the person on supervised probation for a shorter time (e.g., 5 years after her release from incarceration). At what point does the Order operate as to that felon? She may never complete her “term of incarceration” (10 years). After she serves the active time of 3 years, it will be another 5 years before she will have completed her term of supervised release (after which she is not at risk of violating the terms of her supervised probation). But even then, the period of her suspended time will extend for another 7 years before she is free of the risk of serving the balance of her sentence if she violates the laws of the Commonwealth. For some crimes, whatever the actual sentence is, if any portion of it is suspended, it is suspended for a period equal to the maximum sentence that could have been imposed. Would the Order ever apply to that felon? Although it is unnecessary for the disposition of the case before this Court, in a proper case, another Court might find the Order too ambiguous to be enforced.

Although he purports to act under the broad “authority vested in [the Governor] under Article V, Section 12, of the Constitution of Virginia,” what the Governor has done is ordered “the removal of the political disabilities consequent upon conviction of a felony imposed by Article II, Section 1, of the Constitution of Virginia ” [emphasis added] on certain felons. With no further expansion of the scope of the removal of political disabilities, the Governor has also purportedly “restored [to them] ... (3) the right to serve on a jury... .”

It is, at best, an ambiguous pronouncement. The Governor conflates his power to restore civil rights with his authority to remove political disabilities, apparently assuming that they are the same thing. That conflation is further apparent in the fifth “whereas” paragraph of the Order: “[T]he Governor is empowered by Article V, Section 12, of the Constitution of Virginia ‘to remove political disabilities consequent upon conviction,’ thus to restore the political rights of any persons disqualified by Article II, Section 1.” He equates removing political disabilities with restoring civil rights, but, of course, that assumes that the imposition of a political disability necessarily impinges on a civil right and that the restoration of a civil right necessarily [414]*414removes a political disability. In the Order, the Governor removed the disabilities (using the plural) “imposed by Article II, Section 1, of the Virginia Constitution,” but that section of the Constitution addresses only the (singular) right to vote, and the language of the section does not impose a disability; it restricts a right. If the only political disabilities removed by the Order are those “imposed by Article II, Section 1,” one must inquire how that limited cure restores “the right to hold public office,” “the right to serve on a juiy,” or “the right to act as a notary public,” none of which is impacted (much less removed) by Article II, Section 1, and not all of which can properly be characterized as “rights.”

The point of the inquiry is sharpened by the fact that, in the Governor’s Summary of the Order (unsigned, but issued on the Governor’s stationery), the entire thrust of the statement runs solely to the restoration of felons’ right to vote. Summary of the Governor’s Restoration of Rights Order (April 22, 2016). Nowhere is there a reference to any of the other three “rights” or any explanation how his removing political disabilities “imposed by Article II, Section 1,” even affects the felon’s eligibility for jury service. The Summary refers to felons’ being prohibited from voting. It speaks to “disenfranchisement laws,” “poll taxes and literacy tests,” to the consolidation of political power for whites. It refers to felons’ being “unable to vote” and to “this law [which] continues to disenfranchise racial minorities and other citizens who have paid their debt to society and are otherwise qualified to vote.”

Curiously (well, given the general lack of precision of the Summaiy, maybe not), it does not inform the reader to what law “this law” refers. To the extent it is referring to the Constitutional provision in Article II, Section 1 (“No person who has been convicted of a felony shall be qualified to vote unless his civil rights have been restored by the Governor”), the reference to “this law” does not seem to recognize that it is more than a mere statutory enactment; it is, after all, a provision of the Constitution of the Commonwealth of Virginia, proposed to and adopted by the people of the Commonwealth. However the Governor chooses to equate an act of the General Assembly with a provision in the fundamental contract that is the supreme law of the Commonwealth, he must recognize that the latter is not amendable by the General Assembly without the approval of the citizens, and it certainly is not to be unilaterally amended by the Executive Branch, however imperial it might fancy itself to be (no doubt following the example of the Executive Branch of another sovereign). In any event, the fact is that “this law” refers only to the right to vote, and that limited focus emphasizes the objective to be achieved by the Order.

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Bluebook (online)
92 Va. Cir. 412, 2016 Va. Cir. LEXIS 82, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-broce-vaccaugusta-2016.