Michael Brumfield v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedMay 14, 2024
Docket1564233
StatusUnpublished

This text of Michael Brumfield v. Commonwealth of Virginia (Michael Brumfield 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
Michael Brumfield v. Commonwealth of Virginia, (Va. Ct. App. 2024).

Opinion

COURT OF APPEALS OF VIRGINIA UNPUBLISHED

Present: Judges Fulton, Causey and Raphael

MICHAEL BRUMFIELD MEMORANDUM OPINION* v. Record No. 1564-23-3 PER CURIAM MAY 14, 2024 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF CAMPBELL COUNTY John T. Cook, Judge

(Charles E. Haden, on brief), for appellant.

(Jason S. Miyares, Attorney General; Susan Foster Barr, Senior Assistant Attorney General, on brief), for appellee.

Michael Brumfield appeals the trial court’s judgment that he remains a sexually violent

predator under Code § 37.2-910 and that he did not meet the criteria for conditional release under

Code § 37.2-912. He argues that the evidence failed to prove that (1) he remained a sexually

violent predator, or (2) there was “no less restrictive alternative than involuntary secure inpatient

treatment.” We find the trial court’s factual findings to be supported by the evidence. We

further find that oral argument is unnecessary because “the appeal is wholly without merit.”

Code § 17.1-403(ii)(a); Rule 5A:27(a).

* This opinion is not designated for publication. See Code § 17.1-413(A). BACKGROUND1

In reviewing a trial court’s judgment that a respondent is a sexually violent predator, we

view the facts in the light most favorable to the Commonwealth. DeMille v. Commonwealth, 283

Va. 316, 318 (2012). “We also accord the Commonwealth the benefit of all inferences fairly

deducible from the evidence.” Shivaee v. Commonwealth, 270 Va. 112, 127 (2005). The

relevant facts here are not in dispute.

In 2002, Brumfield was convicted of misdemeanor sexual battery after “three instances of

sexual behavior with a 12-year-old boy” at a school they attended when Brumfield was 17. In

2007, Brumfield was convicted of forcible sodomy after he inserted his penis into his

two-year-old nephew’s mouth. Brumfield said he committed that offense to “punish” his

“irritating” nephew through humiliation, similar to how his father and other authority figures had

punished him. Brumfield admitted that he had “no business being alone with children,”

acknowledging that he could “be an asshole” and could “objectify anyone [into being a sex

object].” For the 2007 offense, the trial court sentenced Brumfield to ten years’ incarceration

with six years suspended.

In 2010, finding Brumfield to be a sexually violent predator under Code § 37.2-900, the

court committed him to the custody of the Department of Behavioral Health and Developmental

Services for inpatient treatment. At an annual review hearing in June 2011, the court

conditionally released Brumfield from the Department’s custody. But Brumfield soon violated

the conditions of his release by watching pornography for ten hours each day and being

dishonest with his probation officer and treatment provider. In December 2014, the trial court

1 Portions of the record in this case are sealed. We unseal only the specific facts stated in this opinion, “finding them relevant to our decision.” Daily Press, LLC v. Commonwealth, 301 Va. 384, 393 n.1 (2022). “The remainder of the previously sealed record remains sealed.” Levick v. MacDougall, 294 Va. 283, 288 n.1 (2017). -2- revoked Brumfield’s conditional release and recommitted him to the Department’s custody for

inpatient treatment.

In March 2017, the trial court again conditionally released Brumfield for outpatient

treatment. He later violated the conditions of his release by engaging in sexual acts with his

massage therapist, removing his GPS ankle monitor, and absconding from supervision. The

court revoked his release and returned him to inpatient treatment. The trial court conditionally

released Brumfield a third time in April 2020. But Brumfield again violated his conditions. He

had a “GPS violation,” developed “deviant thoughts” about seeking a prostitute, and tested

positive for morphine while denying any substance abuse. In July 2021, the trial court found that

he remained suitable for outpatient treatment despite having violated his conditions of release.

Within a year, however, Brumfield again violated the conditions of his release

by: 1) creating a YouTube channel and engaging in on-line gaming without permission; 2) lying to his probation officer about accessing the internet; 3) possessing unauthorized electronic devices; 4) having sexual contact with unreported partners; and 5) possessing on his electronic devices sexually explicit images and videos of himself engaging in sexual relations with unidentified females.

The trial court held a revocation hearing in November 2022 and found that Brumfield was no

longer a suitable candidate for conditional release. The court recommitted him to the

Department’s custody for inpatient treatment at the Virginia Center for Behavioral

Rehabilitation.

In August 2023, the circuit court held an annual review hearing. Doctors William

McKenna and Craig King, licensed clinical psychologists, evaluated Brumfield before the

hearing. McKenna reported that Brumfield had been diagnosed with “Other Specified

-3- Personality Disorder, With Antisocial and Narcissistic Personality Traits.”2 He explained that

Brumfield’s disorder “manifested in deficits in interpersonal functioning, impulse control and

emotional self-regulation”; he was “impulsive,” “ha[d] difficulty managing sexual impulses,”

and “historically lacked remorse for his behavior.” McKenna said that Brumfield’s exploitation

of women showed a “lack of empathy” and a “sense of entitlement.”

In the months since his recommitment, Brumfield had reached the second of three phases

of treatment at the Center. Although he engaged in treatment and had no rule violations,

Brumfield had not yet identified his “personal offense pathways” or a “motivation for making

changes.” And he had not shown “honesty regarding all aspects of [his] sex offending history

that are relevant to treatment.” McKenna explained that Brumfield’s “good behavior” in the

Center’s “highly structured” environment did not mean he was ready for conditional release.

Brumfield talked to McKenna about his actions during his most recent conditional

release, which included “filming three women while engaging in sexual activity with them.”

Brumfield claimed that the women had consented to being filmed, but nothing corroborated his

claim. McKenna testified that Brumfield might have exploited the women, and Brumfield

admitted that he had “an attraction to ‘being powerful’ and [that] he [found] it arousing when

women are in a vulnerable situation.”

McKenna concluded that Brumfield was “at [an] extremely high risk for re-offense”

given his “high sex drive,” “impaired volitional capacity,” and actions on prior conditional

releases. McKenna was concerned about Brumfield’s expressed “need to have ‘easy sex,’”

“offensive attitudes,” and interest in “vulnerable victims (e.g., women with difficult

backgrounds).” McKenna believed that Brumfield’s condition could not be sufficiently

2 He also diagnosed Brumfield with alcohol and cannabis use disorder, both in “sustained remission.” -4- “monitored outside of [the Center]” because he would violate the conditions of any release.

McKenna concluded that Brumfield remained a sexually violent predator who was not a suitable

candidate for conditional release.

Dr. King also concluded that Brumfield remained a sexually violent predator who did not

meet the criteria for conditional release. King found that, along with his personality disorder,

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Related

Com. v. Squire
685 S.E.2d 631 (Supreme Court of Virginia, 2009)
Lotz v. Com.
672 S.E.2d 833 (Supreme Court of Virginia, 2009)
Shivaee v. Com.
613 S.E.2d 570 (Supreme Court of Virginia, 2005)
MacDougall v. Levick
805 S.E.2d 775 (Supreme Court of Virginia, 2017)

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Michael Brumfield v. Commonwealth of Virginia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-brumfield-v-commonwealth-of-virginia-vactapp-2024.