Ronald James Williams, Jr. v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedJune 13, 2023
Docket0373221
StatusUnpublished

This text of Ronald James Williams, Jr. v. Commonwealth of Virginia (Ronald James Williams, Jr. 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
Ronald James Williams, Jr. v. Commonwealth of Virginia, (Va. Ct. App. 2023).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Humphreys, Huff and Lorish UNPUBLISHED

Argued at Norfolk, Virginia

RONALD JAMES WILLIAMS, JR. MEMORANDUM OPINION * BY v. Record No. 0373-22-1 JUDGE LISA M. LORISH JUNE 13, 2023 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF THE CITY OF CHESAPEAKE Randall D. Smith, Judge Designate1

Michelle C.F. Derrico, Senior Appellate Attorney (Virginia Indigent Defense Commission, on briefs), for appellant.

Mason D. Williams, Assistant Attorney General (Jason S. Miyares, Attorney General, on brief), for appellee.

Ronald James Williams, Jr. (“Williams”) appeals from his convictions for forcible sodomy

of a child under thirteen while Williams was over the age of eighteen, two counts of indecent

liberties with a child under fifteen, and two counts of aggravated sexual battery. Williams contends

that the trial court erroneously admitted a video depicting the child victim’s forensic interview and a

letter disclosing her alleged sexual abuse under Code § 19.2-268.3, which creates a hearsay

exception for specific statements by child victims of certain crimes. Williams also argues that the

evidence was insufficient to sustain his convictions because the victim’s testimony was inherently

incredible. Finally, Williams asserts that the trial court’s imposition of the mandatory life sentence

* This opinion is not designated for publication. See Code § 17.1-413. 1 Judge Randall D. Smith presided at the jury trial and entered the final sentencing order in this matter. Judge Rufus A. Banks, Jr., presided at the hearing on the Commonwealth’s motion in limine to admit the child victim’s out-of-court statements under Code § 19.2-268.3. for the forcible sodomy conviction violated the Eight Amendment’s prohibition against cruel and

unusual punishment. We affirm the trial court’s judgment.

BACKGROUND 2

In the summer of 2017, twenty-nine-year-old Williams lived in an apartment with his

partner, Francine Williams (“Francine”), and their four children. The family included

Williams’s and Francine’s daughter K.W., who was then ten years old, and her sister, who was

eleven years old. Williams or another relative would watch the children at the apartment while

Francine worked twelve-hour shifts. Williams continued to reside with his family until late

December 2017, when he was incarcerated for an unrelated offense. 3 Francine and the children

moved to a new residence soon after.

In April or May 2018, while Williams was incarcerated, K.W.’s sister texted Francine a

photograph of a letter K.W. had written alleging that Williams had sexually abused her. 4

Francine told Williams’s probation officer about the letter but did not report K.W.’s alleged

abuse to police because Francine had an outstanding arrest warrant and feared losing custody of

her children.

On September 27, 2018, Jenna Spagnuolo conducted a video-recorded forensic interview

of K.W. regarding her alleged abuse. K.W. told Spagnuolo that when she was ten years old,

2 On appeal, we review the evidence “in the ‘light most favorable’ to the Commonwealth, the prevailing party in the trial court.” Hammer v. Commonwealth, 74 Va. App. 225, 231 (2022) (quoting Commonwealth v. Cady, 300 Va. 325, 329 (2021)). 3 The record does not reflect the circumstances of Williams’s incarceration. 4 The letter stated, “I don’t know if I already told you but did I ever tell you that daddy always use to sexual harase [sic] or however you say it but have I told you that daddy . . . . Never mind.” The letter also stated that Williams “[a]lways touch my behind”; “[t]ells me to touch his dingaling”; and “forced me to suck his dingaling.” Finally, the letter stated, “[T]hat’s why sometimes I don’t love him and sometimes I am actually happy that he is in jail so he won’t do them things to me.” -2- Williams “sexually harass[ed]” her multiple times at her apartment while her mother was at

work. K.W. said that Williams would “touch” and “rub[]” her “behind” with his hand and tell

her to “suck [his] dingaling.” Once, Williams took her to his bedroom, and ordered her to rub

his penis through his clothing; when she refused, he grabbed her hand and forced her to do so.

Another time, Williams forced her to fellate him by grabbing her head and moving her mouth

“back and forth” on his penis. During the interview, K.W. confirmed the allegations contained

in her letter to her sister, which she read aloud at Spagnuolo’s request. K.W. also said that her

siblings were present during one incident when Williams touched her buttocks.

On March 5, 2019, a grand jury indicted Williams for forcible sodomy of a child under

thirteen while he was over the age of eighteen, two counts of indecent liberties with a child under

fifteen, and two counts of aggravated sexual battery. Before trial, the Commonwealth moved to

admit K.W.’s letter and the video of her forensic interview under Code § 19.2-268.3. Qualified

“as an expert in child forensic interviews and child abuse,” Spagnuolo testified at a hearing on

the motion that she conducted K.W.’s forensic interview in “a neutral setting” and followed

“nationally recognized protocols and evidence-based research” in doing so. Before the

interview, Spagnuolo made “no determination as to what happen[ed] next with the

investigation.” Spagnuolo testified that K.W. responded to questions in an “age-appropriate

manner” and did not seem “scared” during the interview, although K.W. became “tearful” when

she discussed her abuse. Spagnuolo authenticated a copy of the forensic interview video and,

without objection, the Commonwealth played a portion of it for the trial court. 5

During argument on the Commonwealth’s motion, Williams asserted that the forensic

interview video would be “more prejudicial than probative and cumulative” of K.W.’s

5 At the hearing on the motion in limine, the Commonwealth did not introduce the forensic interview video as a formal exhibit, and the record is ambiguous as to exactly what portions of the video the trial court reviewed. -3- anticipated testimony at trial. Acknowledging that K.W. could “identify the written statement”

and “identify herself in the video,” Williams argued that “it would be more appropriate to hear

directly from [K.W.]” regarding those statements. He also argued K.W.’s in-person testimony

was necessary to satisfy Williams’s “right to confront and cross-examine the witness against

him.” Williams did not object to admission of the letter.

Expressly considering the factors enumerated in Code § 19.2-268.3, the trial court found

that K.W. had “personal knowledge of the event” because “she is the victim.” The trial court

further found that “[t]he letter that [K.W.] authored to her sister, the recorded interview would

support the finding of credibility.” Continuing, the trial court found that K.W. “did not have any

motive to falsify or distort the events,” the forensic interview “provide[d] sufficient safeguards

against any bias or coercion,” Williams had an “opportunity” to commit the alleged acts of abuse

“while the mother was at work,” and “[i]t appears from the interview that [K.W.] did not suffer

from any pain or distress in making her statements.” Therefore, the trial court concluded that

“the time, content, and totality of the circumstances surrounding the statement supplies sufficient

indicia of reliability so as to render it inherently trustworthy.” (Emphasis added). The trial court

also found that the Confrontation Clause would be satisfied because K.W.

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