Justin Ray Dutcher v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedApril 28, 2026
Docket0183252
StatusUnpublished

This text of Justin Ray Dutcher v. Commonwealth of Virginia (Justin Ray Dutcher 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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Justin Ray Dutcher v. Commonwealth of Virginia, (Va. Ct. App. 2026).

Opinion

COURT OF APPEALS OF VIRGINIA

Record No. 0183-25-2

JUSTIN RAY DUTCHER v. COMMONWEALTH OF VIRGINIA

Present: Chief Judge Decker, Judges Beales and Athey Opinion Issued April 28, 2026*

FROM THE CIRCUIT COURT OF THE CITY OF COLONIAL HEIGHTS Steven B. Novey, Judge

(Sante J. Piracci, on brief), for appellant. Appellant submitting on brief.

(Jason S. Miyares,1 Attorney General; Anna M. Hughes, Assistant Attorney General, on brief), for appellee.

MEMORANDUM OPINION PER CURIAM

Justin Ray Dutcher appeals his conviction for possession of Schedule I or II controlled

substance in violation of Code § 18.2-250. He argues that the trial court erred by denying his

motion to strike a juror for cause. We hold the trial court did not err and affirm the conviction.2

* This opinion is not designated for publication. See Code § 17.1-413(A). 1 Jay C. Jones succeeded Jason S. Miyares as Attorney General on January 17, 2026. 2 Having examined the briefs and record in this case, the panel unanimously agrees that oral argument is unnecessary because “the facts and legal arguments are adequately presented in the briefs and record, and the decisional process would not be significantly aided by oral argument.” See Code § 17.1-403(ii)(c); Rule 5A:27(c). Counsel for the appellant waived oral argument. BACKGROUND3

In December 2023, Colonial Heights Police Officer Tristan Bennett encountered Justin Ray

Dutcher during a traffic stop. Dutcher, the driver of the stopped car, appeared “very anxious.”

Officer Bennett saw a passenger in the front seat and a white substance within a glass smoking

device “by the shift column.” Dutcher admitted that the smoking device was his. Officers arrested

him for possession of Schedule I or II controlled drugs. The police searched the car and found over

sixty grams of methamphetamine, packaging materials, and more than $600 in cash.

Dutcher was indicted for possessing a controlled substance with the intent to distribute. He

elected to be tried by a jury. During voir dire, the trial court asked the prospective jurors if they

were “aware of any bias or prejudice” they might have for either party or if they knew of any reason

that they could not be impartial. Venireman J.B., the subject of the issue on appeal, did not raise his

hand or indicate he could not judge the case on the evidence presented at trial.4 All the potential

jurors agreed that they could enforce the law even if they disagreed with it. When the

Commonwealth asked the prospective jurors if they or anyone in their families had been prosecuted

in the City of Colonial Heights, J.B. responded affirmatively but confirmed that he could remain

impartial. In response to a defense question, J.B. explained that, about forty years ago, his younger

brother “had a drug issue.” But J.B. stated that he could “put all that aside.”

After voir dire, the Commonwealth’s attorney made a motion to strike J.B. for cause

because he was the prosecutor in a prior case involving J.B. himself. In response, defense counsel

asked for an opportunity to rehabilitate J.B. The trial court found that J.B. did not need any

rehabilitation because he affirmed that he could be fair. Nonetheless, the court allowed the parties

3 On appeal of the process of jury selection, this Court reviews the evidence in the light most favorable to the Commonwealth, as the prevailing party below. See Keepers v. Commonwealth, 72 Va. App. 17, 25 (2020). 4 We refer to the venireman by his initials to protect his privacy. -2- to bring J.B. back for additional questioning. The Commonwealth’s attorney then withdrew his

motion to strike J.B. for cause. But at that point Dutcher asked to strike J.B. for cause “based on the

same thing.”

J.B. returned to the courtroom yet again for further questioning. He confirmed that he could

decide the case based only on the evidence presented and could give both parties a fair trial. In

response to questioning, J.B. said that at one point he had “an issue with drugs” but had “never

[been] caught for using” them. He conceded that he had been charged with assault and battery in

2004 but said he did not know who prosecuted him and did not remember if he was convicted. He

opined that he was not treated unfairly and emphasized that nothing from his experience would

affect his ability to be fair in this case.

Dutcher again made a motion to strike J.B. for cause “based on his answers.” The

Commonwealth objected and emphasized that the 2004 case against J.B. had been nolle prossed,

likely explaining why J.B. did not recall the outcome of the matter. The trial court denied the

motion. The Commonwealth used a peremptory strike to excuse J.B. from the venire.

The jury found Dutcher guilty of the lesser offense of possession of a Schedule I or II

controlled substance. He was sentenced to ten years of incarceration with seven years and six

months suspended.

ANALYSIS

Dutcher contends that the trial court erred by denying his motion to strike J.B. for cause.

We disagree for the reasons that follow.

“[J]uror impartiality is [a question] of fact,” and a trial court’s decision to seat a juror “is

‘entitled to great deference on appeal’ unless ‘plainly wrong or unsupported by the record.’”

Harvey v. Commonwealth, 76 Va. App. 436, 454 (2023) (quoting Huguely v. Commonwealth, 63

Va. App. 92, 121, 127 (2014)); see Townsend v. Commonwealth, 270 Va. 325, 329 (2005).

-3- Accordingly, “the trial court’s exercise of judicial discretion in deciding challenges for cause will

. . . not [be] disturbed on appeal[] unless manifest error appears in the record.” Taylor v.

Commonwealth, 67 Va. App. 448, 455 (2017) (quoting Jackson v. Commonwealth, 267 Va. 178,

191 (2004)); see Andrews v. Commonwealth, 280 Va. 231, 256 (2010). “A manifest error occurs

when the record shows that a prospective juror cannot or will not lay aside his or her preconceived

opinion.” Taylor, 67 Va. App. at 456. “In conducting our review, we consider the juror’s entire

voir dire, not merely isolated statements.” Ramos v. Commonwealth, 71 Va. App. 150, 157 (2019)

(quoting DeLeon v. Commonwealth, 38 Va. App. 409, 413 (2002)); accord Thomas v.

Commonwealth, 279 Va. 131, 164 (2010).

Both the United States and Virginia Constitutions guarantee the “right to be tried by an

impartial jury.” Northcraft v. Commonwealth, 78 Va. App. 563, 587 (2023); see Code § 8.01-358

(outlining the process for safeguarding this right). “For that guarantee to be effective, persons

accused of violating criminal laws must be provided with ‘an impartial jury drawn from a panel . . .

free from exceptions.’”5 Taylor v. Commonwealth, 61 Va. App. 13, 22 (2012) (quoting Breeden v.

Commonwealth, 217 Va. 297, 300 (1976)). “Every prospective juror must stand indifferent to the

cause . . . .” Id. at 23. And the guarantee requires that “any reasonable doubt as to a juror’s

qualifications must be resolved in favor of the accused.” Northcraft, 78 Va. App. at 587 (quoting

Breeden, 217 Va. at 298). “If . . . a reasonable doubt [exists about] whether the juror possesses

these qualifications, that doubt is sufficient to [e]nsure his exclusion.” Taylor, 61 Va. App. at 23

(quoting Breeden, 217 Va. at 298); see Green v. Commonwealth, 262 Va. 105, 118 (2001). “These

principles must be strictly applied, and when a prospective juror equivocates about whether he or

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Related

Thomas v. Com.
688 S.E.2d 220 (Supreme Court of Virginia, 2010)
Townsend v. Com.
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590 S.E.2d 520 (Supreme Court of Virginia, 2004)
Green v. Commonwealth
546 S.E.2d 446 (Supreme Court of Virginia, 2001)
Lovos-Rivas v. Commonwealth
707 S.E.2d 27 (Court of Appeals of Virginia, 2011)
Cecilio DeLeon v. Commonwealth of Virginia
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Smith v. Commonwealth
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DeHart v. Commonwealth
456 S.E.2d 133 (Court of Appeals of Virginia, 1995)
Justus v. Commonwealth
266 S.E.2d 87 (Supreme Court of Virginia, 1980)
Breeden v. Commonwealth
227 S.E.2d 734 (Supreme Court of Virginia, 1976)
Griffin v. Commonwealth
454 S.E.2d 363 (Court of Appeals of Virginia, 1995)
George Wesley Huguely, V v. Commonwealth of Virginia
754 S.E.2d 557 (Court of Appeals of Virginia, 2014)
Amanda Barbara Nichole Taylor v. Commonwealth of Virginia
796 S.E.2d 859 (Court of Appeals of Virginia, 2017)
Slade v. Commonwealth
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Taylor v. Commonwealth
733 S.E.2d 129 (Court of Appeals of Virginia, 2012)

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