Eric Marvin Laney v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedDecember 6, 2022
Docket0833212
StatusPublished

This text of Eric Marvin Laney v. Commonwealth of Virginia (Eric Marvin Laney v. Commonwealth of Virginia) 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
Eric Marvin Laney v. Commonwealth of Virginia, (Va. Ct. App. 2022).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Chief Judge Decker, Judge O’Brien and Senior Judge Haley PUBLISHED

Argued at Richmond, Virginia

ERIC MARVIN LANEY OPINION BY v. Record No. 0833-21-2 JUDGE MARY GRACE O’BRIEN DECEMBER 6, 2022 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF NEW KENT COUNTY B. Elliott Bondurant, Judge

Ivan D. Fehrenbach (D.R. Dansby, Ltd, on briefs), for appellant.

Matthew J. Beyrau, Assistant Attorney General (Jason S. Miyares, Attorney General, on brief), for appellee.

Eric Marvin Laney appeals his conviction and sentence for distribution of fentanyl, third

offense, in violation of Code § 18.2-248(C). He argues the court erred by permitting victim impact

evidence at sentencing and by declining to apply the accommodation reduction in Code

§ 18.2-248(D). He also argues the court violated his constitutional rights and imposed “an

unreasonably high and arbitrary sentence.” For the following reasons, we affirm.

BACKGROUND

Pursuant to a plea agreement, Laney pled guilty to distribution of fentanyl, third offense, in

violation of Code § 18.2-248(C). The agreement provided that Laney’s “active period of

incarceration will be no more than twenty-five (25) years,” and it permitted Laney to argue at

sentencing for a reduction in the charge to distribution as an accommodation under Code

§ 18.2-248(D). The court accepted the plea agreement, entered a conviction order, and continued

the matter for sentencing. The Commonwealth proffered evidence during Laney’s guilty plea, and Laney presented

additional facts about his accommodation request at sentencing. In accordance with our appellate

standard of review, we state the facts in the light most favorable to the Commonwealth, the

prevailing party below. See Gerald v. Commonwealth, 295 Va. 469, 472-73 (2018).

Samantha Rigdon and her six-year-old son lived with Samantha’s mother, Deborah Rigdon

(“Rigdon”). On January 28, 2019, Rigdon picked up her grandson from daycare. When they came

home, the child discovered Samantha unresponsive in her bedroom and called out for his

grandmother. Rigdon ran into the room and immediately realized Samantha was dead. Next to her

body was a lottery ticket with powder, later determined to be heroin and fentanyl. An autopsy

report listed Samantha’s cause of death as heroin, fentanyl, and citalopram1 intoxication.

Samantha and Laney had exchanged Facebook messages the day she died. In one message,

Samantha wrote, “your coming now? im so sick.” A narcotics expert testified that this language

meant Samantha was going through opiate withdrawal. After her death, Laney admitted to

investigators that he provided Samantha with the drugs that killed her. In an interview with news

reporters, he also acknowledged giving her the drugs.

At sentencing, Laney testified that he and Samantha met while on work release from jail.

According to Laney, they were both struggling with drug addiction, often got high together, and

would not “leave each other sick.” The day she died, Samantha called Laney several times and told

him that she was “sick” and suffering from withdrawal. Laney told her that he did not have any

money to buy drugs.

Samantha asked Laney to get drugs from “Earl,” a dealer who often fronted them drugs.

Samantha had $70, so Laney obtained drugs from Earl and took them to Samantha’s house. He and

1 Citalopram is a prescription antidepressant that Samantha was taking at the time of her death. -2- Samantha divided the drugs, used some, and split the rest. Laney took the $70 from Samantha, left

with his portion of the drugs, and brought the money to Earl. After Laney left, Samantha wrote

him, “man, thank you. I can finally get up and get myself together. be safe.” Laney admitted that

by facilitating the transaction, he was able to obtain drugs for himself and “got to get high,” but he

testified that he was “heartbroke[n]” when he learned that Samantha had died.

During the sentencing hearing, Laney objected to Rigdon’s victim impact statement and

testimony regarding the death of her daughter. The court overruled the objection and permitted both

the statement and testimony.

Laney argued that his conviction should be reduced to distribution as an accommodation

under Code § 18.2-248(D).2 The court denied the request, stating, “[T]his is not an accommodation.

You profited from it, maybe not monetarily, but you didn’t have to pay for the drugs. She paid for

them. You ingested them. You took some home.” The court did not disturb its prior order

convicting Laney of distribution of fentanyl, third offense, and it sentenced him to 50 years’

incarceration, with 25 years suspended.

ANALYSIS

I. Victim Impact Evidence

Laney contends that the court erred by considering Rigdon’s victim impact testimony and

written statement because she does not fit the definition of “victim” in the Crime Victim and

Witness Rights Act, Code §§ 19.2-11.01 to -11.4. See Code § 19.2-11.01(B). He also asserts that

the court’s consideration of that evidence violated his constitutional rights to due process and to be

free from cruel and unusual punishment.

2 The sentencing range for distribution of fentanyl, third offense, is from ten years to life in prison. Code § 18.2-248(C). By contrast, an accommodation distribution under Code § 18.2-248(D) is punishable as a Class 5 felony, with a sentencing range of one to ten years’ imprisonment, or confinement in jail for not more than 12 months and/or a fine not to exceed $2,500. Code § 18.2-10(e). -3- We review a court’s evidentiary rulings, including those made at sentencing, for an abuse of

discretion. See Harvey v. Commonwealth, 65 Va. App. 280, 286-87 (2015). Issues of statutory

interpretation are questions of law that this Court reviews de novo. Baldwin v. Commonwealth, 69

Va. App. 75, 81 (2018).

The Crime Victim and Witness Rights Act gives certain statutorily defined victims the right

to, among other things, “prepare a written victim impact statement” and “testify prior to sentencing

of a defendant.” Code § 19.2-11.01(A)(4)(a), (c). Here, the court found that Rigdon met the

statute’s definition of victim because she was “a person who has suffered physical, psychological,

or economic harm as a direct result of the commission of . . . a felony.” Code § 19.2-11.01(B)(i)(a)

(emphasis added).

On appeal, Laney argues the court made an error of law in determining that Rigdon suffered

as a “direct result” of his drug-distribution felony and abused its discretion by considering the victim

impact evidence at sentencing.

We need not decide whether Rigdon meets the statutory definition of victim because the

record demonstrates that her testimony and written statement were admissible under Rock v.

Commonwealth, 45 Va. App. 254 (2005).3

In Rock, we held that nothing in the Crime Victim and Witness Rights Act prohibits a court

from admitting relevant evidence or testimony from other witnesses who do not meet the statutory

definition of “victim.” Id. at 261-63; see also Smith v. Commonwealth, 27 Va. App. 357, 363

(1998) (noting that a “court must take into account a wide range of information” at sentencing).

Although these other witnesses do not have statutorily protected rights to testify or present written

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Banks v. Com.
701 S.E.2d 437 (Supreme Court of Virginia, 2010)
Alston v. Com.
652 S.E.2d 456 (Supreme Court of Virginia, 2007)
Beck v. Commonwealth
484 S.E.2d 898 (Supreme Court of Virginia, 1997)
Scott v. Commonwealth
707 S.E.2d 17 (Court of Appeals of Virginia, 2011)
Joyce v. Commonwealth
696 S.E.2d 237 (Court of Appeals of Virginia, 2010)
Thomas v. Commonwealth
633 S.E.2d 229 (Court of Appeals of Virginia, 2006)
Rock v. Commonwealth
610 S.E.2d 314 (Court of Appeals of Virginia, 2005)
Foster v. Commonwealth
567 S.E.2d 547 (Court of Appeals of Virginia, 2002)
Smith v. Commonwealth
499 S.E.2d 11 (Court of Appeals of Virginia, 1998)
Barlow v. Commonwealth
494 S.E.2d 901 (Court of Appeals of Virginia, 1998)
Ohree v. Commonwealth
494 S.E.2d 484 (Court of Appeals of Virginia, 1998)
Stillwell v. Commonwealth
247 S.E.2d 360 (Supreme Court of Virginia, 1978)
Tevein Dewayne Harvey v. Commonwealth of Virginia
777 S.E.2d 231 (Court of Appeals of Virginia, 2015)
Du v. Commonwealth
790 S.E.2d 493 (Supreme Court of Virginia, 2016)
Gerald, T. v. Commonwealth
813 S.E.2d 722 (Supreme Court of Virginia, 2018)
Roland Baldwin v. Commonwealth of Virginia
815 S.E.2d 809 (Court of Appeals of Virginia, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Eric Marvin Laney v. Commonwealth of Virginia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-marvin-laney-v-commonwealth-of-virginia-vactapp-2022.