Neal v. Commonwealth's Attorney

60 Va. Cir. 440
CourtVirginia Circuit Court
DecidedJanuary 3, 2003
DocketCase No. CL02000936
StatusPublished
Cited by1 cases

This text of 60 Va. Cir. 440 (Neal v. Commonwealth's Attorney) is published on Counsel Stack Legal Research, covering Virginia 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, 60 Va. Cir. 440 (Va. Super. Ct. 2003).

Opinion

By Judge Clifford R. Weckstein

Howard F. Neal, who was convicted in 1993 of statutory burglary and attempted grand larceny, returns to the trial court pursuant to 2001 legislation. By motion filed on September 6, 2002, he seeks (a) a new scientific investigation of human biological evidence related to the case, pursuant to Virginia Code § 19.2-327.1; and (b) storage, preservation and retention of human biological evidence collected in the case, under Code § 19.2-270.4:1. For reasons that follow, the court grants the second motion but denies the first.

Convicted in a bench trial, Neal was sentenced on March 16, 1993. He unsuccessfully appealed and, also without avail, sought collateral relief in both state and federal court. The record in the underlying criminal case, Case No. CR 92-1388, is incorporated in these proceedings. (Judge Diane McQ. Strickland, who presided in the case, retired from active service on October 31,2002.)

Motion for Scientific Analysis

Petitioner Neal (sometimes herein referred to as “defendant,” the position he held at trial) seeks new scientific testing of hair samples. He contends that advanced DNA hair-sample testing, now conducted by the Division of [441]*441Forensic Science, but not available at the time of trial, could eliminate him as the person whose hairs were found in and around the crime victim’s bed.

The pertinent provisions of Code § 19.2-327.1 provide that any felon may ask the court in which he or she was convicted to order “a new scientific investigation of any human biological evidence related to the case that resulted in the felony conviction,” if the court is satisfied by clear and convincing evidence that “the testing is materially relevant, noncumulative, and necessary and may prove the convicted person’s actual innocence,” and that at the time the conviction became final in the trial court, the evidence had not been tested “because the testing procedure was not available at the Division of Forensic Science;” and there is a sufficient chain of custody “to establish that the evidence has not been altered, tampered with, or substituted;” and “the testing requested involves a scientific method employed by the Division of Forensic Science; and the convicted person has not unreasonably delayed the filing of the petition after the evidence or the test for the evidence became available at the Division of Forensic Science.”

In accordance with the provisions of § 19.2-327, once Neal’s motion was received and filed by the Clerk,1 a copy was served on the Attorney for the Commonwealth. The statute requires that the motion be heard no fewer than thirty, nor more than ninety, days after filing. The court accordingly heard the matter on December 4, 2002. The Commonwealth was represented by Ann Gardner, Senior Assistant Commonwealth’s Attorney; the defendant, who is incarcerated, was not present.

The trial record requires the court to find, as I do, that the defendant fails to state a claim upon which relief can be granted: Scientific testing cannot “prove the convicted person’s actual innocence.” (Emphasis added.) The [442]*442requested testing thus is neither materially relevant nor necessary, though it would be noncumulative.

Since scientific testing could not prove Neal’s innocence, the Court need not determine whether the statute’s other requirements have been met. See Strickland v. Washington, 466 U.S. 668, 697, 80 L. Ed. 2d 674, 700,104 S. Ct. 2052 (1984). Without dispute from the Commonwealth, the court will conclude, for present purposes, that Neal seeks testing, not available in 1992-1993, which involves a scientific method now employed by the Division of Forensic Science; that this petition was filed without unreasonable delay; that any formal defects in the petition could be cured; and (without finding and without evidence or proffer of evidence) that the hair sample evidence still exists, and that it has not been altered, tampered with, or substituted. Neal’s other motion, discussed below, seeks to assure that the evidence is preserved.

Exhibit 2, admitted in evidence in Neal’s trial by stipulation, is a Certificate of Analysis that shows that “Hairs and/or fibers” from a T-shirt, a bedsheet, and pillow cases were submitted for laboratory examination. The defendant apparently is African-American. The victim of the crimes for which he was prosecuted apparently is Caucasian. According to the Certificate of Analysis “no Negroid hairs were present in the ‘hairs and/or fibers’ from the pillow cases”; from the T-shirt, “one characteristically Negroid hair fragment of no value for meaningful comparison purposes was present”; from the bedsheet, two “characteristically Negroid hair fragments of no value for meaningful comparison purposes were present.”

Neal’s direct appeal challenged the sufficiency of the evidence. In its order denying the appeal, the Court of Appeals mistakenly stated that, “an African-American hair matching the defendant’s [was] found on Mrs. Butz’s [the victim’s] bed sheet.” (Emphasis added.) Neal v. Commonwealth, Record No. 0643-93-3, June 10, 1994. The record demonstrates that Neal is absolutely correct in stating that there is no evidence that hairs which matched his were found at the crime scene.

There are other reasons, however, to conclude, as did the Court of Appeals, that the evidence was “sufficient to sustain the defendant’s convictions for burglary and attempted robbery.”

First, Mrs. Butz’s identification of the defendant was reliable. Mrs. Butz had an opportunity to know the defendant’s voice because for a month prior to the burglary she had numerous conversations with him about her yard work. One conversation lasted around thirty minutes. On the night of the burglary when Mrs. Butz heard “give me money”, she immediately recognized the voice as belonging to the [443]*443defendant. The words, upon which the identification was based, were spoken directly in her ear. Mrs. Butz immediately gave the police the defendant’s name at the crime scene. She testified at trial unequivocally concerning her certainty of defendant’s identity, and her demeanor in giving that testimony was the subject of comment by the trial judge [who was the trier of fact]. ... The sufficiency of the evidence to establish identity is a question for the trier of fact. The fact finder accepted Mrs. Butz’s identification of the defendant. “The weight which should be given to evidence and whether the testimony of the witnesses credible or questions which the fact finder must decide.” ....
Second, the circumstantial evidence in this case leaves no reasonable hypothesis of innocence.... The defendant’s wet T-shirt, along with a vegetable peeler, was found outside the Butz’s bedroom door on the night of the crime when it was raining. The defendant knew where Mrs. Butz’s money was located and the layout of the Butz’s home. He had used tools from the Butz’s basement. He had the motive.

Id. (citations omitted). Though Neal espouses a different view of the weight and effect of the evidence, familiar principles of appellate review required the Court of Appeals to examine the evidence in the light most favorable to the Commonwealth, the party which prevailed in the trial court, and to give the Commonwealth the benefit of all reasonable inferences that fairly could be drawn from the evidence. See King v. Commonwealth, 264 Va.

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Related

Neal v. Commonwealth's Attorney of Roanoke
70 Va. Cir. 159 (Roanoke County Circuit Court, 2006)

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Bluebook (online)
60 Va. Cir. 440, Counsel Stack Legal Research, https://law.counselstack.com/opinion/neal-v-commonwealths-attorney-vacc-2003.