Randy Jurden Largen v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedMay 19, 2026
Docket0624253
StatusUnpublished

This text of Randy Jurden Largen v. Commonwealth of Virginia (Randy Jurden Largen 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
Randy Jurden Largen v. Commonwealth of Virginia, (Va. Ct. App. 2026).

Opinion

COURT OF APPEALS OF VIRGINIA

Record No. 0624-25-3

RANDY JURDEN LARGEN v. COMMONWEALTH OF VIRGINIA

Present: Judges Malveaux, Athey and Frucci Argued at Lexington, Virginia Opinion Issued May 19, 2026*

FROM THE CIRCUIT COURT OF THE CITY OF MARTINSVILLE G. Carter Greer, Judge

Jason S. Eisner for appellant.

Tanner M. Russo, Assistant Attorney General (Jason S. Miyares,1 Attorney General, on brief), for appellee.

MEMORANDUM OPINION BY JUDGE CLIFFORD L. ATHEY, JR.

On February 4, 2025, a jury empaneled in the Circuit Court of the City of Martinsville

(“trial court”) convicted Randy Jurden Largen (“Largen”) of first-degree murder and statutory

burglary. On appeal, Largen contends that the trial court erred by 1) refusing to strike two jurors

for cause, 2) allowing statements of the decedent to be admitted at trial, 3) refusing to give a jury

instruction on manslaughter, and 4) denying his motions to strike the evidence. Finding no error,

we affirm.

* This opinion is not designated for publication. See Code § 17.1-413(A). 1 Jay C. Jones succeeded Jason S. Miyares as Attorney General on January 17, 2026. I. BACKGROUND2

While police were responding to a 911 hang-up call from an apartment complex, they

observed the victim of an assault, C.M.,3 in a parking lot exhibiting extensive injuries consistent

with having received multiple blows. C.M. identified Largen as the individual who had

assaulted and battered her, resulting in C.M. succumbing to her injuries nearly two weeks later.

Largen was subsequently charged with first-degree murder, in violation of Code § 18.2-32,

statutory burglary, in violation of Code § 18.2-91, and felony murder, in violation of Code

§ 18.2-32.

A. The Commonwealth’s motion in limine

The Commonwealth filed a motion in limine seeking to admit a recorded statement from

the decedent, C.M., in evidence. In support of its pretrial motion in limine, the Commonwealth

proffered that the evidence to be introduced at trial would prove that around 7:07 a.m. on July

23, 2020, the Martinsville Police Department received two 911 calls from a phone number

belonging to C.M. However, both 911 calls had been terminated before the dispatcher could

answer either call. The Commonwealth also proffered that at about 7:22 a.m., Officer Cody

King (“Officer King”) was responding to the apartment complex where the 911 call originated.

Officer King was flagged down by C.M. and made contact with her in the parking lot of the

2 “On appeal of challenges to the admissibility of evidence, the sufficiency of the evidence to support a conviction, and constitutional issues, appellate courts view the evidence in the light most favorable to the Commonwealth.” Drexel v. Commonwealth, 80 Va. App. 720, 731 n.2 (2024). But in reviewing a trial court’s ruling on a proposed jury instruction, this Court “view[s] the evidence in the light most favorable” to the proponent of the instruction, which is Largen. Pena Pinedo v. Commonwealth, 300 Va. 116, 118 (2021) (quoting Commonwealth v. Vaughn, 263 Va. 31, 33 (2002)). “Consequently, this opinion sets out all of the evidence relevant to the issues before the Court.” Drexel, 80 Va. App. at 731 n.2. Additionally, “[t]o the extent that this opinion mentions facts found in the sealed record, we unseal only those specific facts, finding them relevant to the decision in this case. The remainder of the previously sealed record remains sealed.” Levick v. MacDougall, 294 Va. 283, 288 n.1 (2017). 3 We use initials to protect the privacy of the victim. -2- Virginia Museum of Natural History. C.M. initially failed to respond when asked what had

happened to her; however, after a short pause, C.M. advised law enforcement that “[h]e hit me.”

She further described how “the guy next door to [her]” broke into her apartment and beat her.

The officers noted that C.M. was visibly injured and bleeding while describing what had

occurred. The Commonwealth then described and played body-worn camera video that depicted

C.M. “trembling, . . . upset, . . . [and] nervous.” C.M. then told law enforcement that she thought

“he” was going to kill her. Also during the body-worn camera footage, C.M. explained that “he

kept knocking real hard” and that “part of [her] door was open, so [she] pushed it back.” The

video footage also recorded C.M. claiming that Largen was “raging” so she “pushed [her] door to

shut it, and he pushed it open.” C.M. further claimed that Largen “came back in” the apartment

and she “played dead.”

Based upon the proffered testimony and video footage, the Commonwealth requested that

the trial court rule in limine that the hearsay statements of C.M. were admissible in evidence as

either an excited utterance or as a dying declaration. Largen contended in response that the

hearsay statements of C.M. were not an excited utterance because she “had the presence of

mind” to drive nearly a mile from the crime scene before “calm[ly] and concise[ly]” giving “a

speech about what happened to her” to the responding officers. Largen also asserted that the

admission of C.M.’s hearsay statements would “violate [his] [C]onfrontation [C]lause rights.”

The trial court subsequently ruled that although the hearsay statements were not admissible as

dying declarations, they were admissible as excited utterances. In support, the trial court opined

that C.M. was “just spouting off” when talking to the officers and that she was speaking “almost

as if the officer was not there.” Although the trial court granted the Commonwealth’s motion in

limine to admit the hearsay statements as excited utterances, the trial court limited the admissible

-3- hearsay statements of C.M. to those made by C.M. and recorded during the first minute and ten

seconds of the body-worn camera video.

Following the pre-trial ruling, the Commonwealth stated that it would “submit

that . . . this is a continued objection,” to which Largen’s counsel and the trial court agreed. The

Commonwealth further stated, “To the extent that I am able to bind my client, the

Commonwealth of Virginia, I agree that I am waiving contemporaneous objection to the Rule, to

the admission of this evidence.” The Commonwealth stated that Largen’s counsel “already fairly

preserved it” and that Largen’s counsel “doesn’t need to do it and potentially impact the view of

the [j]ury on him or his client by continuing to object.” The trial court noted Largen’s objection

to the ruling, to which Largen’s counsel responded, “I guess[] any objection I might make

contemporaneously is being handled at this time.” The trial court agreed. In its written ruling

entered the same day as the hearing, the trial court stated that “[a]fter hearing the evidence and

argument of counsel,” it “sustained the [m]otion in [l]imine regarding the excited utterance and

denied the motion regarding the dying declaration.” Neither the trial court’s oral nor written

rulings mentioned the Confrontation Clause.

B. Voir Dire

On the morning of trial, February 4, 2025, Largen’s counsel informed the trial court that

he had “prepared clothes” for Largen to wear during the trial but Largen “wanted to wear his jail

attire.” The trial court asked Largen whether he “want[ed] to wear an orange jumpsuit,” and

Largen stated that “[t]he clothes [are] not an issue.” After asking Largen many additional

questions concerning his proposed attire during the trial, the trial court stated on the record that

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