Commonwealth v. Giles

87 Va. Cir. 320, 2013 Va. Cir. LEXIS 135
CourtRoanoke County Circuit Court
DecidedDecember 10, 2013
DocketCase Nos. CJ13000031 and CJ13000032
StatusPublished

This text of 87 Va. Cir. 320 (Commonwealth v. Giles) is published on Counsel Stack Legal Research, covering Roanoke 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. Giles, 87 Va. Cir. 320, 2013 Va. Cir. LEXIS 135 (Va. Super. Ct. 2013).

Opinion

By Judge Charles N. Dorsey

The parties are before the Court on appeals filed by both the defendant, Paul Stuart Giles, and the Commonwealth stemming from a commitment review hearing held by the Roanoke City Juvenile and Domestic Relations Court (“Juvenile Court”) on September 25, 2013.

In his appeal, Giles asks the Court to review the Juvenile Court’s September 25 order continuing his indeterminate commitment with the Department of Juvenile Justice. In turn, the Commonwealth asks the Court to void the Juvenile Court’s setting of an appeal bond at the September 25 hearing because that court lacked jurisdiction over the matter pursuant to Va. Code § 16.1-289.

For the reasons that follow, the Court finds that this case is properly before it and will hear the matter de novo.

Factual and Procedural Background

On June 27, 2013, the Juvenile Court found Giles guilty of a probation violation. Adjudication Hearing, Case No. JJ028909-19-00, June 27, 2013. On July 25, 2013, the Juvenile Court found Giles guilty of Assault and Battery, Va. Code § 18.2-57.2. Juvenile Commitment Order, July 25, 2013. Accordingly, that court ordered Giles to be placed in indeterminate commitment with the Department of Juvenile Justice and scheduled a commitment review hearing for September 23, 2013. Disposition Order - Delinquency, Case No. JJ028909-19-00, July 25,2013, Juvenile Commitment Order, July 25, 2013. In its Disposition Order, the Juvenile Court also noted its denial of a “request to appeal” by one of the parties, presumably the defendant. Disposition Order - Delinquency Case, [321]*321July 25, 2013. Immediately following that note is a parenthetical that states “[n]ot a final order.” Id.

According to the Commonwealth, the Juvenile Court rescheduled the commitment review hearing for September 25, 2013. Commonwealth’s Mot. to Appeal the Setting of the Appeal Bond ¶ 3. At that hearing, the Commonwealth argued that the Juvenile Court no longer had jurisdiction over the matter under Va. Code § 16.1-289 because more than sixty days elapsed since the July 25 hearing. Id.

The chain of events that followed is less clear, and the record offers little guidance. Apparently, the Juvenile Court rejected the Commonwealth’s jurisdictional argument, and, by its Disposition Notice of September 25, continued Giles’ indeterminate commitment with the Department of Juvenile Justice. Disposition Notice, Case No. JJ02890918- 00, Sept. 25, 2013. The September 25 notice does not note any appeal or set an appeal bond.

The Juvenile Court entered a second Disposition Notice on September 26. Disposition Notice, Case Nos. JJ028909-18-00, JJ02890919- 00, Sept. 26, 2013. In that second notice, the Court continued Giles’ indeterminate commitment but noted appeals in both the assault and battery and probation violation cases. That second notice also set a secured appeal bond of $1,000.00. Id.

Confusing matters further, however, the Juvenile Court’s records also include a “Disposition of Delinquency” form from the September 25 hearing that purports to “amend[] the prior disposition,” orders Giles to “complete commitment,” and recommends that Giles serve the “minimum length of stay.” Review Hearing - Disposition of Delinquency/ Child in Need of Services or Supervision, Case Nos. JJ028909-18-00, JJ028909-19-00, Sept. 25, 2013. A handwritten amendment on that form dated September 26 sets a $1,000.00 unsecured appeal bond in the case. Id.

The defendant filed his appeal of the Juvenile Court’s September 25 decision the very same day, and the Commonwealth noted its appeal of the Juvenile Court’s September 25 decision on October 3. The parties appeared before this court on October 21, 2013, and the Commonwealth moved the Court to set aside the appeal bond based on the same Va. Code § 16.1-289 jurisdictional argument it made in the Juvenile Court. The Court denied that motion. Meanwhile, Giles turned eighteen on October 19,2013, and moved from juvenile detention to the Roanoke City Jail.

Analysis

The Commonwealth asks the Court to void the Juvenile Court’s September 25 decision setting an appeal bond because that court lacked jurisdiction to hold the commitment review hearing on September 25 pursuant to Virginia Code § 16.1-289 as more than sixty days had passed since the original commitment hearing date. The Commonwealth also [322]*322argues that Giles failed to perfect his appeal within ten days from the Juvenile Court’s original commitment order on July 25. Giles appeals the Juvenile Court’s September 25 decision continuing his indeterminate commitment with the Department of Juvenile Justice.

Because the Commonwealth’s argument is jurisdictional, the Court must address that argument first.

A. An appeal may be taken to the circuit court within ten days from the entry of any final order, judgment, or conviction of the juvenile court and will be heard de novo. Va. Code § 16.1-296(A). “A de novo hearing means a trial anew . . . [and] a trial de novo in the circuit court annuls the judgment of the juvenile court as completely as if there had been no previous trial....” Alexander v. Flowers, 51 Va. App. 404, 413, 658 S.E.2d 355, 359 (2008) (internal quotations omitted). Indeed, a trial de novo in the circuit court means the appealing party has the right to a trial “unhampered and unprejudiced by the lower court’s ruling.” Id. at 414, 658 S.E.2d at 359 (internal quotations omitted). A court hearing a case de novo “which hears evidence anew and new evidence, and which makes final disposition of the case, acts not as a court of appeals but as one exercising original jurisdiction.” Id. at 413, 658 S.E.2d at 359 (quoting Addison v. Salyer, 185 Va. 644, 650, 40 S.E.2d 260, 263 (1946)).

A “delinquency or commitment order is a final order.” Richardson v. Commonwealth, 28 Va. App. 389, 391-92, 504 S.E.2d 884, 885 (1998). Additionally, “a commitment review order revoking, modifying, or continuing the commitment is [also] a final, appealable order as to the decision whether to revoke, modify, or continue the commitment.” Id.

Virginia Code § 16.1-289 addresses the review of commitment orders and states:

[t]he juvenile court or the circuit court, as the case may be, of its own motion may reopen any case and may modify or revoke its order. The . . . court shall before modifying or revoking such order grant a hearing after notice in writing to the complainant, if any, and to the person or agency having custody of the child; provided, however, that this section shall not apply in the case of a child committed to the Department after sixty days from the date of the order of commitment.

Thus, a trial judge has no authority to consider additional matters, modify, or revoke a commitment order more than sixty days after the date of the order of commitment. Washington v. Commonwealth, No. 1002-06-4, 2007 Va. App. lexis 278, at *11 (Va. App. July 24, 2007). An order stemming from a commitment review hearing held more than sixty days after the original commitment order is void ab initio because the court lacks jurisdiction. See

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Related

Congdon v. Commonwealth
705 S.E.2d 526 (Court of Appeals of Virginia, 2011)
Alexander v. Flowers
658 S.E.2d 355 (Court of Appeals of Virginia, 2008)
Richardson v. Commonwealth
504 S.E.2d 884 (Court of Appeals of Virginia, 1998)
Dennis Holland v. Commonwealth of Virginia
749 S.E.2d 206 (Court of Appeals of Virginia, 2013)
Addison v. Salyer
40 S.E.2d 260 (Supreme Court of Virginia, 1946)
Gravely v. Deeds
40 S.E.2d 175 (Supreme Court of Virginia, 1946)

Cite This Page — Counsel Stack

Bluebook (online)
87 Va. Cir. 320, 2013 Va. Cir. LEXIS 135, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-giles-vaccroanokecty-2013.