Michael Randolph Vaughan v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedFebruary 1, 2022
Docket1440203
StatusUnpublished

This text of Michael Randolph Vaughan v. Commonwealth of Virginia (Michael Randolph Vaughan 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 Randolph Vaughan v. Commonwealth of Virginia, (Va. Ct. App. 2022).

Opinion

COURT OF APPEALS OF VIRGINIA UNPUBLISHED

Present: Judges Humphreys, AtLee and Raphael Argued at Lexington, Virginia

MICHAEL RANDOLPH VAUGHAN MEMORANDUM OPINION* BY v. Record No. 1440-20-3 JUDGE RICHARD Y. ATLEE, JR. FEBRUARY 1, 2022 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF PITTSYLVANIA COUNTY James J. Reynolds, Judge

Mark T. Williams (Williams & Light, on brief), for appellant.

Craig W. Stallard, Senior Assistant Attorney General (Mark R. Herring, 1 Attorney General, on brief), for appellee.

Following a bench trial, the circuit court convicted appellant Michael Randolph Vaughan

of attempted first-degree murder, aggravated malicious wounding, shooting from a vehicle, and

use of a firearm in the commission of a felony. On appeal, he argues the circuit court erred by

(1) “denying [him] from impeaching [a prosecution] witness”; (2) finding sufficient evidence of

intent to kill to support a conviction of attempted murder; and (3) finding Vaughan acted with

malice, rather than in self-defense, or without malice. For the following reasons, we disagree

and affirm.

* Pursuant to Code § 17.1-413, this opinion is not designated for publication. 1 Jason S. Miyares succeeded Mark R. Herring as Attorney General on January 15, 2022. I. BACKGROUND

“On appeal of criminal convictions, we view the facts in the light most favorable to the

Commonwealth, and [we] draw all reasonable inferences from those facts.” Payne v.

Commonwealth, 65 Va. App. 194, 198 (2015).

On August 12, 2019, Vaughan and the victim, Eric Clay, were drinking together at

Vaughan’s house. Vaughan and Clay had known each other for at least ten years. They decided

to visit Clay’s cousin, Jasmine Jamerson, who lived twelve to fifteen miles from Vaughan. Clay

and Vaughan remained at Jamerson’s for about an hour to an hour-and-a-half, talking to

Jamerson and her husband and playing with their two daughters.

Clay testified that he had a couple “swallows” of bourbon, meaning full mouthfuls of

liquor from the bottle, at Vaughan’s house before they left. He testified that he did not drink at

Jamerson’s. Jamerson testified that Vaughan was drinking “some” at her house and that Clay

“maybe took a swallow,” but “[i]t wasn’t no heavy drinking.” She said Vaughan was “a little

tipsy” but that the visit was pleasant, with no fighting and everyone “laughing and carrying on

just like any other time.”

After leaving Jamerson’s, Clay took Vaughan to look at a fishing spot about fifty yards

from Jamerson’s house. They then headed back towards Vaughan’s house. On the drive, Clay

testified that Vaughan asked him to slow down and that he responded that he was only “running

like forty or forty-five” miles per hour. He continued “the next thing I know I was, I see like a

flash on the side of my head that, and like a loud boom and I, I really don’t remember anything

after that.” At no point did Vaughan ask Clay to pull over, stop driving, or attempt to take

control of the vehicle.

Clay woke up in the hospital. He had a bullet wound below his right temple and had lost

vision in his left eye. As a result, he can no longer obtain a Commercial Driver’s License for -2- work. Bullet fragments remain in his skull due to the risks of removing them. Medical records

from the hospital indicated that Clay had a 0.13 blood alcohol content when he was admitted, as

well as traces of benzodiazepine and cannabinoid in his system. Clay testified that he had taken

Valium and CBD to explain the latter two results.2

At the close of the Commonwealth’s case-in-chief, Vaughan moved to strike the

evidence, arguing in part that the evidence failed to establish the requisite intent. The circuit

court denied the motion, saying “[i]f a gun is pointed at a person’s head, at close range and fired

into the side of their head, there is not a whole lot of leap that you need to make in terms of what

the intent was at the time that gun was fired.” After the defense presented its witnesses,

Vaughan renewed the motion to strike, which the circuit court denied. Vaughan received a

ten-year sentence for attempted first-degree murder, which was suspended in full; a twenty-year

sentence for aggravated malicious wounding, with eight years suspended; a seven-year sentence

for shooting from a vehicle, which was suspended in full; and a three-year mandatory minimum

sentence for the use of a firearm in the commission of a felony, for a total active sentence of

fifteen years in prison. This appeal followed.

II. ANALYSIS

Vaughan first argues that the circuit court ought to have permitted him to cross-examine

Clay about a 2014 incident where Clay weaved while driving under the influence. He also raises

various challenges to the sufficiency of the evidence of intent, arguing that the evidence failed to

show he had specific intent to support the attempted murder charge and that his claim of

self-defense negated any evidence of malice.

2 An expert for the defense testified that cannabinoid would only have shown up in testing if an individual took something containing THC. CBD, the non-intoxicating compound derived from cannabis, does not show up on this test. -3- A. Impeachment Evidence

We review a circuit court’s decision to exclude impeachment evidence, like other

evidentiary rulings, for an abuse of discretion. Hicks v. Commonwealth, 71 Va. App. 255, 275

(2019). Under this “deferential standard[,] . . . [o]nly in those cases [in which] ‘reasonable

jurists could not differ has an abuse of discretion [supporting a reversal] occurred.’” Id. (fourth

and fifth alterations in original) (quoting Campos v. Commonwealth, 67 Va. App. 690, 702

(2017)).

Vaughan argues that the circuit court erred when it did not permit him to cross-examine

Clay about an incident from 2014 where Clay was weaving while driving under the influence.

He alleges that such evidence was permissible and probative as it “contradicted Clay’s claim that

he was not weaving on the highway as asserted by [Vaughan].” He also argues that any past acts

of weaving are “probative on the issue of credibility.” This weaving was relevant, he claims,

because it supported his claim of self-defense, as he purportedly shot Clay out of fear for his life

based upon Clay’s reckless driving.

“Except as provided in Rule 2:413 or by statute, evidence of other crimes, wrongs, or acts

is generally not admissible to prove the character trait of a person in order to show that the

person acted in conformity therewith.” Va. R. Evid. 2:404(b). This rule exists to exclude

improper propensity evidence, which is precisely what Vaughan sought to introduce here, as he

was attempting to establish that Clay weaved on August 12, 2019, because he purportedly also

weaved in 2014.

Vaughan argues that this was admissible impeachment evidence under Virginia Rule of

Evidence 2:607(a)(vii) and (viii). Under Virginia’s Rules of Evidence,

the credibility of a witness may be impeached by any party other than the one calling the witness, with any proof that is relevant to

-4- the witness’s credibility. Impeachment may be undertaken, among other means, by:

....

(vii) contradiction by other evidence; and

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