Kenneth Calvin Knight v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedAugust 16, 2022
Docket0787214
StatusUnpublished

This text of Kenneth Calvin Knight v. Commonwealth of Virginia (Kenneth Calvin Knight 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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Kenneth Calvin Knight v. Commonwealth of Virginia, (Va. Ct. App. 2022).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges O’Brien, Malveaux and Callins UNPUBLISHED

Argued at Alexandria, Virginia

KENNETH CALVIN KNIGHT MEMORANDUM OPINION* BY v. Record No. 0787-21-4 JUDGE DOMINIQUE A. CALLINS AUGUST 16, 2022 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF ARLINGTON COUNTY Daniel S. Fiore, II, Judge

Bradley R. Haywood (Office of the Public Defender, on brief), for appellant.

Lindsay M. Brooker, Assistant Attorney General (Jason S. Miyares, Attorney General, on brief), for appellee.

Kenneth Calvin Knight appeals the circuit court’s revocation of his suspended sentences

and imposition of a two-year active sentence. Knight contends that (1) the circuit court erred in

finding him guilty of and sentencing him for probation violations alleging new criminal conduct,

despite lacking an evidentiary basis for doing so; (2) the circuit court erred in finding that its

probation violation orders contained clerical errors that could be corrected pursuant to Code

§ 8.01-428; (3) the circuit court erred in making substantive changes to probation violation

orders over which it had lost jurisdiction; (4) the circuit court erred by failing to consider

mitigating evidence, considering and giving weight to irrelevant evidence, and improperly

weighing evidence in its revocation of his suspended sentences; and (5) the circuit court erred in

imposing a sentence for technical violations that exceeded the limitations established in Code

§ 19.2-306.1 and was disproportionate to similarly situated defendants, in violation of the Fifth,

* Pursuant to Code § 17.1-413, this opinion is not designated for publication. Eighth, and Fourteenth Amendments. For the following reasons, we affirm the judgment of the

circuit court and remand to correct the remaining clerical mistakes in the circuit court’s nunc pro

tunc orders for Case Nos. CR16-1595(04) and CR16-1596(04).

BACKGROUND

On September 20, 2016, Knight pleaded guilty to grand larceny and credit card theft in

the Circuit Court of Arlington County. On February 10, 2017, the circuit court sentenced him to

four years’ imprisonment with all but one year and six months suspended for the grand larceny

charge and three years’ imprisonment, all suspended, for the credit card theft charge, with the

sentences to run consecutively. The circuit court also ordered that Knight would be placed on

supervised probation for five years. On January 11, 2019, the circuit court granted Knight’s

motion to perform community service in the Offender Aid and Restoration (“OAR”) program in

lieu of paying court costs. On June 17, 2019, OAR submitted a letter to the circuit court stating

that Knight had completed no community service hours, had not been in communication with

OAR for two months, and had not paid the OAR program fee. On June 20, 2019, the circuit

court issued a rule against Knight under Case Nos. CR16-1595(02) and CR16-1596(02)

requiring him to appear in court to show cause why his probation should not be revoked for his

violations with OAR.

On July 30, 2019, a probation officer submitted a major violation report stating that

Knight had violated the conditions of his probation by testing positive for marijuana eighteen

times, failing to report for scheduled drug testing seven times, failing to report to supervision as

scheduled, moving out of his brother’s home without permission, and absconding. The circuit

court then issued a bench warrant for Knight’s arrest the next day under Case Nos.

CR16-1595(03) and CR16-1596(03) alleging that Knight had violated his probation for the

reasons stated in the major violation report. Knight did not appear for his hearing on the rule to

-2- show cause, and the circuit court issued another bench warrant for Knight’s arrest on August 13,

2019 alleging that Knight had violated his probation by failing to appear for the show cause

hearing. About a year later, Knight was arrested on the court’s bench warrants, and the Office of

the Public Defender was appointed to represent him.

On October 14, 2020, the probation officer submitted a major violation addendum stating

that Knight had several new criminal charges pending in Washington, D.C. The circuit court

issued a rule against Knight on October 15, 2020, under Case Nos. CR16-1595(04) and

CR16-1596(04) to show cause why his probation should not be revoked for failing to obey all

federal, state, and local laws and ordinances. After several continuances, Knight’s first

revocation hearing was held on February 5, 2021. During the hearing, Knight admitted the

probation violations for Case Nos. CR16-1595(02) and (03) and CR16-1596(02) and (03), while

denying the good behavior allegations in Case Nos. CR16-1595(04) and CR16-1596(04), since

his criminal charges in D.C. were still pending. The circuit court continued the matter to March

19, 2021, so that Knight could be evaluated for admission into the Addictions, Corrections, and

Treatment (“ACT”) Unit program. The circuit court offered that the continuance would also

give defense counsel “an opportunity to see if he can provide the Court a reasonable alternative

to the ACT Unit.”

At the March 19, 2021 hearing, defense counsel informed the circuit court that Knight

was ineligible for the ACT program. The circuit court stated that “we’ll adjudicate the 02 and 03

violations,” and defense counsel reminded the court that Knight was not admitting the probation

violations relating to his pending criminal charges in D.C. and planned to plead not guilty to

those charges. The court then asked, “Is that the 04 one?” and defense counsel responded,

“There are three of them, so I’m not sure.” The court then stated, “It’s the 04. Okay? Yes, sir.

Okay and the 02 and 03 have been admitted.” Defense counsel recommended that Knight be

-3- released from jail and placed back on probation because Knight would be eligible for

community-based services that could help get his life back on track, and he could also live with

his brother while on probation. The circuit court acknowledged that community-based services

would help Knight, but expressed concern that defense counsel had not presented a concrete plan

for Knight to be released on probation. Remaining open to the possibility that it could be

persuaded to place Knight back on probation, the circuit court continued the matter to give

defense counsel time to prepare a concrete plan for Knight’s release.

On April 14, 2021, a mitigation investigator with the Arlington Office of the Public

Defender submitted a written release plan to the circuit court. At a hearing on April 16, 2021,

the Commonwealth argued that the release plan “doesn’t feel like a really fully formed plan” and

“doesn’t quite feel like a reasonable alternative to ACT when I know ACT is very concrete and

structured and specific.” The circuit court then stated, “I think I have to agree with the

Commonwealth. I don’t think this is a very robust or detailed plan. It seems to be . . . more hope

than a plan.” The court continued the matter to allow the probation office to investigate whether

Knight’s brother would prove an appropriate solution to Knight’s housing needs.

At a hearing on April 30, 2021, the probation officer informed the circuit court that

Knight’s brother’s home was a viable housing option for Knight. The Commonwealth

maintained its position that the release plan was not a reasonable alternative to ACT. The circuit

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