James Earl Brown v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedJune 12, 2001
Docket2439001
StatusUnpublished

This text of James Earl Brown v. Commonwealth of Virginia (James Earl Brown 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.

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James Earl Brown v. Commonwealth of Virginia, (Va. Ct. App. 2001).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Willis, Humphreys and Senior Judge Overton Argued at Chesapeake, Virginia

JAMES EARL BROWN MEMORANDUM OPINION * BY v. Record No. 2439-00-1 JUDGE ROBERT J. HUMPHREYS JUNE 12, 2001 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF GLOUCESTER COUNTY William H. Shaw, III, Judge

Charles E. Haden for appellant.

Kathleen B. Martin, Assistant Attorney General (Mark L. Earley, Attorney General, on brief), for appellee.

James Earl Brown appeals his convictions, after a bench

trial, of two counts of grand larceny, two counts of breaking and

entering with intent to commit larceny, abduction, and use of a

firearm in the commission of a felony. 1 Brown contends that the

trial court erred in admitting a statement of Jeff Green as an

adoptive admission, and in failing to grant his motion to strike

the Commonwealth's evidence as insufficient as a matter of law.

* Pursuant to Code § 17.1-413, this opinion is not designated for publication. 1 Brown was also charged with robbery and use of a firearm in the commission of robbery. However, the trial court dismissed these charges on the motion of Brown, finding the evidence insufficient to support them. The evidence presented at trial established that on April

15, 1999, at about 1:30 p.m., Dennis Emerson returned to his

home and saw a blue Ford parked in his yard. He did not see

anyone in the car or at his front door, so he walked to the back

of his home, where he found a young man standing on his deck.

The young man saw Emerson and asked if "Joe Eldridge" lived

there. Emerson replied that he did not. The two then walked

toward the front of the house.

As Emerson approached his garage, he looked toward his

house again and saw another young man walk out of the back door,

with a gun in his right hand. Emerson then turned to the first

young man and saw that he also had a gun, which he was pointing

in Emerson's face. He told Emerson to "Go back," to the deck

and threatened to kill Emerson if he had seen the license plate

number on his Ford. The man then told Emerson to get down on

the ground and said, "Don't you move for five minutes." When

the two men left, Emerson went into his house and called the

police.

Emerson found that his house had been "completely

ransacked." The men had tried to open Emerson's safe by

shooting at it. There were bullets and shell casings on the

floor. The men had taken a five-gallon water cooler containing

about $800 worth of coins, a handgun, a hunting knife and a

watch.

- 2 - Around 2:30 p.m. to 3:00 p.m. that same day, Douglas Hines

returned to his home, near Route 17, to find that his home had

also been burglarized. Several items, including a semiautomatic

Browning 9-mm pistol had been taken.

Late that afternoon, Kimberly Harper received a page from

Jeffrey Green. Green asked Harper to drive him and Brown to

Green's mother's car, which he claimed had broken down. Harper

picked up Green and Brown at a convenience store near Saluda and

took them to a diner on Route 17. The trip took about five

minutes. Green sat in the passenger seat, and Brown sat in the

back. Green told Harper, "they had robbed a man and that he had

held him at gunpoint," "and put him on the ground." Brown said

nothing. Harper described Brown as "look[ing] like he was in

shock." Green and Harper then drove Green's mother's car to

Green's home. Brown followed, driving Harper's car.

At trial, a firearms and toolmark expert testified that the

cartridges and jackets found at Emerson's house had come from

the 9-mm that had been stolen from Hines' home. Brown

stipulated that he had been in possession of that gun on April

16, 1999, the day after the burglaries. However, Emerson

testified that Brown was not the young man who had held him at

gunpoint and was unable to identify Brown as the second

intruder. He testified, "I got enough a [sic] look at him to

know that he was white. He was young. He was slender built.

But to really identify him, no."

- 3 - Brown objected to the admission of the statement made by

Green to Harper, alleging that the statement was hearsay. The

trial court overruled Brown's objection, finding that the

statement constituted an adoptive admission on the part of

Brown, an exception to the hearsay rule.

"The admissibility of evidence is within the broad

discretion of the trial court, and a ruling will not be

disturbed on appeal in the absence of an abuse of discretion."

Blain v. Commonwealth, 7 Va. App. 10, 16, 371 S.E.2d 838, 842

(1988). "As a general rule, when a statement that tends to

incriminate one accused of committing a crime is made in the

presence and hearing of the accused and such statement is not

denied, contradicted, or objected to by him, both the statement

and the fact of the accused's failure to deny the statement are

admissible in a criminal proceeding against the accused."

Strohecker v. Commonwealth, 23 Va. App. 242, 252, 475 S.E.2d

844, 849 (1996).

For the adoptive admission exception to apply, a direct accusation is not essential. Under the adoptive admission exception to the rule against hearsay, a declarant's accusatory or incriminating statements are not admitted to prove the truth of matters asserted. Such statements are admissible because they lay the foundation to show that the defendant acquiesced or admitted to the statement. An adoptive admission avoids the confrontation problem because the words of the hearsay become the words of the defendant. While the hearsay statement merely lays the foundation, the conduct of the accused, by remaining silent and failing

- 4 - to deny it, is admissible as substantive evidence to prove the accused's acquiescence in its truth.

Id. at 254, 475 S.E.2d at 850 (citations omitted).

"The Virginia test regarding the use of adoptive admissions

as an exception to the rule against hearsay is whether [persons]

similarly situated would have felt themselves called upon to

deny the statements affecting them in the event they did not

intend to express acquiescence by their failure to do so."

Knick v. Commonwealth, 15 Va. App. 103, 106, 421 S.E.2d 479, 481

(1992) (citation omitted).

In ruling on the admissibility of adoptive admissions:

the courts have evolved a variety of safeguarding requirements against misuse, of which the following are illustrative. (1) The statement must have been heard by the party claimed to have acquiesced. (2) It must have been understood by him. (3) The subject matter must have been within his knowledge. (4) Physical or emotional impediment to responding must not be present. (5) The personal makeup of the speaker . . . may be such as to make it reasonable to expect denial. (6) Probably most important of all, the statement itself must be such as would, if untrue, call for a denial under the circumstances. . . . The essential inquiry in each case is whether a reasonable person would have denied under the circumstances, with answers not lending themselves readily to mechanical formulations.

Id. at 106-07, 421 S.E.2d at 481 (footnote omitted).

Here, although Harper, a layperson, testified that Brown

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Related

Archer v. Commonwealth
492 S.E.2d 826 (Court of Appeals of Virginia, 1997)
Strohecker v. Commonwealth
475 S.E.2d 844 (Court of Appeals of Virginia, 1996)
Knick v. Commonwealth
421 S.E.2d 479 (Court of Appeals of Virginia, 1992)
Norman v. Commonwealth
346 S.E.2d 44 (Court of Appeals of Virginia, 1986)
Bright v. Commonwealth
356 S.E.2d 443 (Court of Appeals of Virginia, 1987)
Cirios v. Commonwealth
373 S.E.2d 164 (Court of Appeals of Virginia, 1988)
Blain v. Commonwealth
371 S.E.2d 838 (Court of Appeals of Virginia, 1988)
Tucker v. Commonwealth
442 S.E.2d 419 (Court of Appeals of Virginia, 1994)

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