Neal v. Commonwealth's Attorney of Roanoke

70 Va. Cir. 159
CourtRoanoke County Circuit Court
DecidedJanuary 31, 2006
DocketCase No. CL02000963
StatusPublished

This text of 70 Va. Cir. 159 (Neal v. Commonwealth's Attorney of Roanoke) is published on Counsel Stack Legal Research, covering Roanoke County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Neal v. Commonwealth's Attorney of Roanoke, 70 Va. Cir. 159 (Va. Super. Ct. 2006).

Opinion

BY JUDGE CLIFFORD R. WECKSTEIN

Returning to the trial court after unsuccessful excursions to the Court of Appeals and Supreme Court of Virginia, Howard Frank Neal has filed a new pleading, seeking “Scientific Analysis Pursuant to Section 19.2-327.1 of the Code of Virginia” of physical evidence that was gathered in the investigation of crimes he was convicted of in 1993. More than three years ago, when Neal filed a pleading seeking the same thing, I entered a final order denying his request.

The final order denying relief was entered on January 3,2003. Howard F. Neal v. Commonwealth’s Atty. of Roanoke City, CL02-963. The final sentences of that order read: “Nothing further remains to be done, and the Clerk accordingly is directed to remove the cause from the docket and place it among ended common law matters. This is a final order.” An opinion letter, incorporated in the final order, is reported at 60 Va. Cir. 440 (2003). As Mr. Neal noted in his current pleading, there is a clerical error in the date of that opinion letter. Though it is dated January 3,2002, it was issued on January 3, 2003.

[160]*160Along with his request for scientific analysis, Neal filed a motion seeking leave to proceed in forma pauperis, and an affidavit in support of that motion. In order to consider the request for scientific analysis, the court grants the motion for leave to proceed in forma pauperis, and reinstates the cause upon the civil docket.

Neal’s present pleading, in which he analyzes my 2003 decision with lawyer-like precision and concludes that the 2003 judgment was procedurally flawed and legally unsound, must be dismissed, whether or not his analysis is accurate.

Principles of Law

When two suits between the same parties are based on the same cause of action (claim for relief), the legal doctrine of res judicata bars relitigation of any issue or claim that was, or could have been, decided in the first case. Lofton Ridge, L.L.C. v. Norfolk S. Ry., 268 Va. 377, 381, 601 S.E. 2d 649 (2004). (The literal meaning of res judicata is “the thing has been decided.” Nunez Nunez v. Vazquez Irizarry, 367 F. Supp. 2d 201, 203-04 (D. P.R. 2005).

Collateral estoppel is a related, and similar, doctrine. Collateral estoppel says that, when a question of fact that was essential to a valid and final personal judgment was actually litigated in an action, then a party to that first action is barred (“collaterally estopped”) from litigating that issue of fact in any subsequent action. Lofton Ridge, 268 Va. at 381. Collateral estoppel also applies to those who are “privies” of the parties to the first action. Id. Privies are persons having a particular type of close legal interest with the party. See Black’s Law Dictionary 1218 (7th ed. 1999).

Under Rule 1:1 of the Rules of the Supreme Court of Virginia, final orders remain under the control of the trial court and can be modified, vacated, or suspended for 21 days after the date of entiy, “and no longer.” Rule 1:1 bars further litigation of issues that the court had power to decide. Hayes v. Hayes, 3 Va. App. 499, 504, 351 S.E.2d 590, 592 (1986).

History

Following a bench trial in this court, Judge Diane McQ. Strickland found Neal guilty of statutory burglary and attempted robbery. He was sentenced on March 16, 1993, unsuccessfully appealed and, also without [161]*161avail, sought collateral relief in both state and federal court. The record in the underlying criminal case, No. CR92-1388, is incorporated by this reference.

On September 6, 2002, Neal filed civil pleadings in this court. The Clerk assigned Case No. CL02-963 to that civil filing; I have reinstated that case for consideration of Neal’s present filings. Proceeding under a statutory scheme adopted in 2001, he sought, as he seeks now, an order compelling scientific analysis of human biological evidence related to the case in which he was convicted in 1993. See Code § 19.2-327.1. He also asked the court to enter an order directing storage, preservation, and retention of human biological evidence collected in the case.

By order entered on January 3, 2003, incorporating a letter opinion dated Januaiy 3, 2002 [sic], I denied the motion for scientific testing of evidence. In the same order, I granted the motion for preservation of human biological evidence. (At the end of this opinion letter, I set forth the efforts made by the clerk and the Roanoke City Police Department to locate any human biological evidence.)

Neal appealed. On March 25,2003, the Court of Appeals of Virginia, in an order reciting that it did not have jurisdiction over the case, transferred the case to the Supreme Court of Virginia pursuant to Code. § 8.01-677.1. Record No. 0592-03-3. However, on September 12,2003, the Supreme Court decided Gaston v. Gaston, 266 Va. 175, 585 S.E.2d 596 (2003). Also see Harvey v. Warden, 268 Va. 5, 597 S.E.2d 58 (2004), holding that a circuit court’s ruling under Code § 19.2-327.1 is “unappealable.”1 Consequently, on December 3, 2003, the Supreme Court dismissed Neal’s appeal for láck of jurisdiction. Record No. 030484. Neal asked the Supreme Court to set aside its judgment and grant a rehearing, which the Court declined to do. Id., Januaiy 4, 2004.

Neal then changed direction; filing a Petition for Writ of Actual Innocence in the Court of Appeals of Virginia. In a published order, the Court of Appeals summarily denied the Petition. In re Howard Frank Neal, 44 Va. App. 89, 603 S.E.2d 170 (2004). In its order, the Court of Appeals, referring to this court’s ruling on earlier motion for scientific testing, said:

[162]*162Citing the reliability of the victim’s identification of Neal, the circumstantial evidence excluding all reasonable hypotheses of Neal’s innocence, and the trial judge’s indication that she gave no weight to the certificate of analysis, the circuit court concluded DNA testing of the hair samples would not prove Neal’s adual innocence. We agree with this finding. Thus, the certificate of analysis did not affect the outcome of Neal’s trial, and provides no proper basis for the award of a writ of actual innocence.

Id. at 90, n. 1. Neal did not appeal the Court of Appeals’s decision.

Conclusion

Under the provisions of Rule 1:1 and the doctrine of res judicata, Neal’s motion for scientific testing must be dismissed and denied.

To the extent that the Court of Appeals’s agreement with my prior findings and its statements about the certificate of analysis introduced in evidence at Neal’s trial were essential to that Court’s judgment denying Neal’s Petition for Writ of Actual Innocence, collateral estoppel also bars reconsideration of my January 3, 2003, ruling.

An appropriate order will enter.

Retention of Evidence

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Related

LOFTON RIDGE v. Norfolk Southern Ry. Co.
601 S.E.2d 648 (Supreme Court of Virginia, 2004)
Harvey v. Warden of Coffeewood Correctional Center
597 S.E.2d 58 (Supreme Court of Virginia, 2004)
Gaston v. Commonwealth
585 S.E.2d 596 (Supreme Court of Virginia, 2003)
In Re Neal
603 S.E.2d 170 (Court of Appeals of Virginia, 2004)
Hayes v. Hayes
351 S.E.2d 590 (Court of Appeals of Virginia, 1986)
Nunez Nunez v. Vazquez Irizarry
367 F. Supp. 2d 201 (D. Puerto Rico, 2005)
Neal v. Commonwealth's Attorney
60 Va. Cir. 440 (Virginia Circuit Court, 2003)

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Bluebook (online)
70 Va. Cir. 159, Counsel Stack Legal Research, https://law.counselstack.com/opinion/neal-v-commonwealths-attorney-of-roanoke-vaccroanokecty-2006.