Commonwealth's Attorney of Stafford County v. Rosa Serrano

CourtCourt of Appeals of Virginia
DecidedApril 29, 2025
Docket0396244
StatusPublished

This text of Commonwealth's Attorney of Stafford County v. Rosa Serrano (Commonwealth's Attorney of Stafford County v. Rosa Serrano) 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's Attorney of Stafford County v. Rosa Serrano, (Va. Ct. App. 2025).

Opinion

COURT OF APPEALS OF VIRGINIA PUBLISHED

Present: Judges Ortiz, Frucci and Bernhard Argued at Fairfax, Virginia

COMMONWEALTH’S ATTORNEY OF STAFFORD COUNTY OPINION BY v. Record No. 0396-24-4 JUDGE STEVEN C. FRUCCI APRIL 29, 2025 ROSA SERRANO

FROM THE CIRCUIT COURT OF STAFFORD COUNTY J. Bruce Strickland, Judge

Phillip Corliss Krone (Alexander Francuzenko; Cook Craig & Francuzenko, on briefs), for appellant.

David M. Parker (Trevor S. Cox; Simon Sandoval-Moshenberg; Hunton Andrews Kurth LLP; Murray Osorio PLLC, on brief), for appellee.

Michael Dingman, Assistant Solicitor General (Jason S. Miyares, Attorney General; Erika L. Maley, Solicitor General; Graham K. Bryant, Deputy Solicitor General, on brief), for the Commonwealth of Virginia.

Under federal law, immigrants who are victims of certain crimes,1 and who assist law

enforcement in investigating and prosecuting those crimes, may apply for a United States

nonimmigrant status (“U Visa”). 8 U.S.C. § 1101(a)(15)(U)(i)–(iii). Their application must

include “a certification” from a “Federal, State, or local law enforcement official, prosecutor,

judge, or other Federal, State, or local authority investigating [the] criminal activity.” 8 U.S.C.

1 Such crimes include “domestic violence,” “felonious assault,” or “any similar activity.” 8 U.S.C. § 1101(a)(15)(U)(iii). § 1184(1).2 In conjunction with this, Virginia enacted the Certifications for Victims of

Qualifying Criminal Activity Act (“Act”) to provide a procedure for applicants to obtain a

“certification form” from “[c]ertifying official[s]” in Virginia.3 Code § 9.1-1500-1503.

Following a request to complete a certification form from Rosa Serrano, the

Commonwealth’s Attorney of Stafford County (“Commonwealth’s Attorney”) refused to sign

her certification form. As a result, Serrano petitioned the Circuit Court of Stafford County to

review the Commonwealth’s Attorney’s determination, find his failure to certify unreasonable,

execute the certification form, and award her fees and costs. The circuit court held an

evidentiary hearing on her petition. At the end of the hearing, the Commonwealth’s Attorney

presented a written motion requesting that the circuit court find the Act unconstitutional.

Following, the circuit court found in favor of Serrano and awarded her attorney fees in the

amount of $6,400.

The Commonwealth’s Attorney contends the circuit court erred in finding the Act was

constitutional, that he acted unreasonably in refusing to certify Serrano, that he “opined that he

was unable to verify that . . . Serrano was a victim of a qualifying criminal activity,” that attorney

fees and costs were to be awarded, and that the attorney fees amount awarded was appropriate

when the amount was unreasonable and the Commonwealth’s Attorney “was not afforded the

2 The certification includes personal information, information about the agency involved, information about the underlying case and the criminal acts involved, an explanation of how the victim assisted law enforcement, and disclosure of any family members who were culpable in the criminal activity. 3 Under the Act, a “[c]ertification form” is “a certification form or declaration completed by a certifying agency that is required by federal immigration law certifying that a person is a victim of qualifying criminal activity,” a “[c]ertifying official” includes “the head of the certifying agency,” and a “[c]ertifying agency” includes “an attorney for the Commonwealth.” Code § 9.1-1500. -2- opportunity to respond.” For the reasons stated below, this Court affirms the circuit court’s

judgment.

BACKGROUND

In 2022, Serrano was the victim in a criminal case where the defendant was charged with

assault and battery under Code § 18.2-57, strangulation under Code § 18.2-51.6, and prevention

of calling 911 under Code § 18.2-164 (the “criminal case”). On February 16, 2023, the

defendant in the criminal case entered into a plea agreement with the Office of the

Commonwealth’s Attorney in which the strangulation and prevention of calling 911 charges

were nolle prossed in exchange for him pleading guilty to the assault and battery charge.

Consequently, the defendant was convicted of assault and battery. Also on that day, Serrano,

through counsel, delivered a certification form to the Commonwealth’s Attorney’s office that she

had partially filled out.

In May 2023, the Commonwealth’s Attorney responded that it was “not appropriate to

sign” the certification form, but he did not provide an explanation. Counsel for Serrano

requested an explanation for “the denial” and advised that she was going to file for an award of

attorney fees and court costs against the Commonwealth’s Attorney pursuant to Code

§ 9.1-1502. The Commonwealth’s Attorney replied with a letter that stated he had “indicated

that the decision to not certify [the] U Visa application was based on a full review of the case and

the parties involved” and that the response was all he was “required to provide.” However, he

further noted that: (1) the Assistant Commonwealth’s Attorney who prosecuted the criminal case

had not been aware that Serrano had previously filed for a U Visa that the Commonwealth’s

Attorney deemed did not merit certification; (2) Serrano’s “version of the offense in her latest U

Visa application does not match the . . . version of the offense as told to the responding deputy,”

-3- and (3) he could not “say how [this information] would have affected [the] decision to prosecute

the [criminal] case.”

In June 2023, Serrano petitioned the circuit court to review the Commonwealth’s

Attorney’s determination, find his failure to certify unreasonable, execute the certification form,

and award her fees and costs. On August 18, 2023, the circuit court heard argument and received

evidence on the petition. Serrano testified about the underlying criminal case, and her attorney

argued that Serrano was a victim of qualifying criminal activity who assisted with its prosecution

and that the Commonwealth’s Attorney unreasonably refused to certify her form. She contended

that it is not whether a prosecution results in a conviction that controls whether she could qualify

for a U Visa, but whether she was a victim of qualifying criminal activity. With this in mind, she

claimed that strangulation was a “similar activity” to those listed in 8 U.S.C.

§ 1101(a)(15)(U)(iii) and would allow her to qualify for a U Visa.

The Commonwealth’s Attorney did not argue against the claim that strangulation was a

“similar activity” as used in 8 U.S.C. § 1101(a)(15)(U)(iii), instead he argued that “convictions

control the facts,” that it “wasn’t a domestic assault and battery” case, and that he did not believe

Serrano could be found to be “a victim of a qualifying criminal activity as defined under the

code.” He further contended that he acted reasonably because he could not certify the form as

being true when the information in it was not accurate and that he “was not required . . . to give a

written explanation if the reasoning is I just can’t sign this because I’d be committing an act of

perjury.”

In support of this argument, the Commonwealth’s Attorney claimed for the first time that

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Commonwealth's Attorney of Stafford County v. Rosa Serrano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealths-attorney-of-stafford-county-v-rosa-serrano-vactapp-2025.