Jonathan Brenton Griffin v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedAugust 1, 2023
Docket0485224
StatusPublished

This text of Jonathan Brenton Griffin v. Commonwealth of Virginia (Jonathan Brenton Griffin 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
Jonathan Brenton Griffin v. Commonwealth of Virginia, (Va. Ct. App. 2023).

Opinion

COURT OF APPEALS OF VIRGINIA PUBLISHED

Present: Judges Beales, Fulton and Lorish Argued at Richmond, Virginia

JONATHAN BRENTON GRIFFIN OPINION BY v. Record No. 0485-22-4 JUDGE RANDOLPH A. BEALES AUGUST 1, 2023 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA James C. Clark, Judge

Heidi Meinzer (Law Office of Heidi Meinzer, PLLC, on briefs), for appellant.

Katherine Quinlan Adelfio, Assistant Attorney General (Jason S. Miyares, Attorney General, on brief), for appellee.

Following a jury trial, Jonathan B. Griffin, a former police officer with the City of

Alexandria, was convicted of assault and battery for using excessive force against a handcuffed

man in his custody on January 27, 2020. On appeal, Griffin contends that his constitutional due

process rights were violated when the same investigating officer conducted both the

administrative and criminal investigations of the incident. See Garrity v. New Jersey, 385 U.S.

493 (1967). Second, he contends that the trial court erred in overruling his Batson challenge to

the Commonwealth’s use of its peremptory strikes. See Batson v. Kentucky, 476 U.S. 79 (1986).

Third, he contends that the trial court erred by denying the admission of certain evidence

concerning the victim’s character. Fourth, he contends that the trial court did not properly

instruct the jury. Finally, he contends that the evidence was insufficient to prove that he

committed assault and battery. I. BACKGROUND

“In accordance with familiar principles of appellate review, the facts will be stated in the

light most favorable to the Commonwealth, [as] the prevailing party at trial.” Scott v.

Commonwealth, 292 Va. 380, 381 (2016).

A. The Incident

In January 2020, Jonathan B. Griffin worked as a police officer for the City of Alexandria

and as a residential community officer in the apartment building where James Lenzen lived. On

January 27, 2020, Griffin took Lenzen into emergency custody pursuant to his authority as a police

officer under Code § 37.2-808(G).1 Griffin handcuffed Lenzen’s hands behind his back and

transported him to INOVA Alexandria Hospital (the “Hospital”). Security video footage from the

Hospital emergency room that day was entered into evidence at trial and shows Griffin guiding a

compliant Lenzen to the registration desk with a single hand.

Cyd Fields, a Hospital employee, helped to “register [Lenzen] into the [e]mergency [r]oom.”

The security video footage shows Lenzen standing relatively still near the registration desk while he

waited for Griffin and Fields to get him registered. A woman, later identified as Dr. Katherine

Lewis, walked down the hall toward them. Although she turned into a patient room before she

reached them, Griffin decided to move Lenzen a few steps closer to the registration desk. Seconds

later, the security video footage shows that Griffin grabbed Lenzen with both hands and used his

right leg to sweep Lenzen’s legs out from under him. As a result, Lenzen, whose hands were still

A law-enforcement officer who, based upon his observation or the reliable reports of others, has probable cause to believe that a person meets the criteria for emergency custody as stated in this section may take that person into custody and transport that person to an appropriate location to assess the need for hospitalization or treatment without prior authorization.

Code § 37.2-808(G). -2- handcuffed behind his back, fell face-first onto the hard hospital floor, sustained facial injuries

(including a contusion above his right eye and an abrasion to his nose), and broke his kneecap.

At trial, Kelly Godette (a Hospital employee) testified that he saw Griffin and Lenzen at the

registration desk and that he overheard Griffin tell Lenzen “to keep still.” Lenzen was “moving

back and forth” a little bit but “was not harming anybody.” He testified that Griffin then said, “I

told you to keep still,” and swept Lenzen’s legs out from under him. According to Godette, Lenzen

had not made any movements toward Dr. Lewis, Godette, or Griffin and had not made any

movements that suggested that he was going to run.

Fields (who was standing behind Griffin and Lenzen and was at arm’s length from them

during the assault) testified that she did not see Lenzen doing anything immediately before the

assault and did not hear Lenzen say “anything provoking.” She further testified that all she heard

Griffin say was “stop or stop resisting. And the next thing I know, he’s on the floor.” Fields

emphasized that she “didn’t see him [Lenzen] doing any type of resisting.”

Griffin, who numerous individuals stated was generally quite well-regarded as a member of

the police force in Alexandria, testified in his own defense. He agreed that Lenzen was initially

cooperative while they were standing at the registration desk. Griffin then observed “a doctor

moving down the hallway” toward them and claimed that he “asked [Lenzen] to move towards the

registration desk” because he “wanted to create space in that hallway.” According to Griffin,

Lenzen “pulled back and resisted my control of him.” Griffin claimed that he tried to calm Lenzen

down but was unsuccessful, so he then used “a more authoritative voice and told [Lenzen] to stop

resisting.”2 According to Griffin, he decided to put Lenzen on the ground because he thought

2 Paramedic David Fox, who was the farthest eyewitness away from Griffin and Lenzen at the time of the incident who also testified at trial, testified that he heard Griffin tell Lenzen “to calm down, and to not move away from him. To come back over to where he was.” However, Fox acknowledged that he did not “visually lock in” on Griffin and Lenzen during the incident. -3- Lenzen “was putting himself in a position where he could assault me.” At trial, Griffin admitted, “I

didn’t react properly” because he had actually intended to use some technique other than a

leg-swipe to bring Lenzen to the ground.

Griffin further testified that, at the time of the incident, he was concerned about Lenzen. He

knew Lenzen suffered from bipolar disorder. He testified that he was also aware that Lenzen had

“made threats to several government installations and had a previous conviction of arson.” Griffin

also testified that he had heard that Lenzen had assaulted a nurse and a deputy at a mental health

hospital in the past and that Lenzen “had physically confronted firefighters” in the past. However,

Griffin conceded on cross-examination that, on the day in question, Lenzen never said anything to

indicate that he wanted to harm himself or others. Griffin also acknowledged that Lenzen had been

searched for weapons before arriving at the Hospital and remained in handcuffs while at the

Hospital. Furthermore, Griffin admitted that Lenzen had not made any verbal threats toward

Hospital staff and did not indicate that he had tried to bite or spit at anyone in the Hospital.

B. The Investigation

Directly after the incident, Griffin promptly filed a police report and included two

attachments—one containing three pictures of Lenzen’s injuries and one containing the Hospital

security video footage of the incident. Sergeant John East, an internal affairs investigator with

the Alexandria Police Department, reviewed Griffin’s report and initiated an internal

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Jonathan Brenton Griffin v. Commonwealth of Virginia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jonathan-brenton-griffin-v-commonwealth-of-virginia-vactapp-2023.