Desetti v. Chester

CourtSupreme Court of Virginia
DecidedJune 4, 2015
Docket141239
StatusPublished

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

Bluebook
Desetti v. Chester, (Va. 2015).

Opinion

Present: All the Justices

JUDY GAYLE DESETTI OPINION BY v. Record No. 141239 JUSTICE LEROY F. MILLETTE, JR. June 4, 2015 FRANCIS CHESTER, ET AL.

FROM THE CIRCUIT COURT OF AUGUSTA COUNTY A. Joseph Canada, Jr., Judge

In this appeal we determine whether a plaintiff

sufficiently pled a claim for legal malpractice that occurred

during the course of an attorney's representation of the

plaintiff in a criminal matter.

I. FACTS AND PROCEEDINGS

This appeal comes to us upon the circuit court sustaining

a demurrer. "For purposes of evaluating a demurrer, a court

assumes that all material facts, implied facts[,] and

reasonable inferences from those facts that are properly

alleged in the complaint are true." Brown v. Jacobs, ___ Va.

___, ___ n.2, 768 S.E.2d 421, 423 n.2 (2015). Accordingly, the

relevant facts alleged in the complaint are as follows.

Judy Desetti, her husband Joel Desetti, and her son Ryan

Desetti were involved in a criminal incident with a law

enforcement officer at the Desetti home. Arising from that

incident, Judy was charged with felony assault and battery of a

law enforcement officer in violation of Code § 18.2-57, and

misdemeanor obstruction of justice in violation of Code § 18.2- 460. Also arising from that incident, Joel and Ryan were

charged with misdemeanor obstruction of justice in violation of

Code § 18.2-460.

Judy employed Francis Chester of the firm Chester-Cestari

Law, P.C., to represent her in this criminal matter. Chester

was also retained by Joel and Ryan to represent them in their

own criminal proceedings.

Joel's and Ryan's charges of misdemeanor obstruction of

justice went to trial first. Chester called Judy as a witness.

During the course of her direct examination, Judy admitted that

she struck the law enforcement officer who had entered the

Desetti home. At the conclusion of trial, both Joel and Ryan

were found guilty.

Subsequent to that trial, the Commonwealth conveyed to

Chester a plea offer on Judy's charges. The offer allowed Judy

to plead guilty to a misdemeanor assault and battery, rather

than to the felony assault and battery that she had been

charged with. Chester never conveyed this plea offer to Judy

or responded to the Commonwealth. Instead, Chester advised

Judy that she should plead not guilty and go to a jury trial

because "she had a 'slam dunk' case." Chester also failed to

inform Judy that a guilty verdict on her felony charge would

entail a mandatory minimum sentence of six months of

incarceration.

2 Based on Chester's advice, Judy pled not guilty and

requested a jury trial. Judy asserts that various aspects of

Chester's representation during the trial constituted legal

malpractice. Among these allegations of malpractice is

Chester's unilateral decision, without consulting with Judy, to

reject the Commonwealth's jury instruction that incorporated

the lesser-included offense of misdemeanor assault and battery

because Chester was employing a "felony or freedom" strategy.

At the conclusion of that trial, the jury returned a guilty

verdict on the felony assault and battery charge, and Judy was

sentenced to the mandatory minimum of six months of

incarceration. Judy unsuccessfully exhausted her direct

appeals.

One month into her sentence, Judy filed a petition for

writ of habeas corpus alleging that Chester's representation

was so deficient and prejudicial that it deprived her of her

constitutional right to effective assistance of counsel. One

year later, the habeas court granted Judy's habeas petition on

the basis that Chester's ineffective assistance of counsel

prejudiced Judy in the criminal matter. The habeas court held

that Chester's representation was constitutionally deficient

because of (1) Chester's concurrent representation of Judy,

Joel, and Ryan, (2) Chester's failure to convey and explain the

Commonwealth's plea offer, and (3) Chester's failure to advise

3 and consult with Judy regarding the inclusion of a lesser-

included misdemeanor offense in the jury instructions.

The habeas court vacated Judy's felony assault and battery

conviction. The Commonwealth elected to retry Judy for her

actions giving rise to her original charges. During the course

of this second criminal matter, Judy pled guilty to misdemeanor

assault and battery. Pursuant to this plea, Judy was convicted

of misdemeanor assault and battery and was sentenced to ten

days of incarceration, with all ten days suspended.

Judy subsequently filed a legal malpractice claim against

Chester and the firm Chester-Cestari Law. This legal

malpractice claim alleged multiple bases of Chester's

malpractice for actions during the original criminal matter.

Chester and Chester-Cestari Law filed a demurrer to Judy's

complaint. The demurrer asserted that Judy failed to state a

claim upon which relief could be granted because she was not

actually innocent of the criminal act of assault that gave rise

to the criminal matter in which the alleged legal malpractice

occurred. That is, although Judy's felony assault and battery

conviction had been vacated, Judy subsequently admitted guilt

to misdemeanor assault and battery, and it was that guilt of a

criminal act, rather than a guilty verdict for any given crime,

which proximately caused injuries Judy suffered from the

original criminal matter.

4 The circuit court agreed with Chester and the firm

Chester-Cestari Law, and sustained the demurrer without leave

to amend. Judy timely appealed to this Court.

II. DISCUSSION

Although we granted three assignments of error, we need

only address the first assignment because our resolution of the

issue of proximate causation resolves this appeal. 1 Jimenez v.

Corr, 288 Va. 395, 404, 764 S.E.2d 115, 118 (2014).

Assignment of error 1 reads:

1. The trial court erred in sustaining Defendants' Demurrer because it thereby decided, as a matter of law, that [Judy] could not prove that Chester's negligence was the proximate cause of [Judy]'s harm when the trial court had already established by prior order granting [Judy]'s Petition for Writ of Habeas Corpus that it was reasonably probable that Chester's ineffective assistance of counsel caused [Judy] Harm.

A. Standard Of Review

"A trial court's decision sustaining a demurrer presents a

question of law which we review de novo." Harris v. Kreutzer,

271 Va. 188, 195, 624 S.E.2d 24, 28 (2006). "A demurrer

accepts as true all facts properly pled, as well as reasonable

inferences from those facts." Steward v. Holland Family

Props., LLC, 284 Va. 282, 286, 726 S.E.2d 251, 253 (2012).

1 Assignment of error 2 pertains to whether Judy's guilty plea to the misdemeanor charge was equivalent to being convicted of the felony charge. Assignment of error 3 pertains to whether Judy was required to plead actual innocence of all criminal culpability to state a legal malpractice cause of action.

5 B.

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