William Howard Robinson v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedJuly 7, 2020
Docket0154194
StatusPublished

This text of William Howard Robinson v. Commonwealth of Virginia (William Howard Robinson 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
William Howard Robinson v. Commonwealth of Virginia, (Va. Ct. App. 2020).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Chief Judge Decker, Judge Humphreys, and Senior Judge Annunziata Argued by teleconference PUBLISHED

WILLIAM HOWARD ROBINSON OPINION BY v. Record No. 0154-19-4 JUDGE ROBERT J. HUMPHREYS JULY 7, 2020 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF PRINCE WILLIAM COUNTY Kimberly A. Irving, Judge

Ché C. Rogers, for appellant.

Kelsey M. Bulger, Assistant Attorney General (Mark R. Herring, Attorney General, on brief), for appellee.

On November 7, 2016, a grand jury indicted appellant William Howard Robinson

(“Robinson”) in the Circuit Court of Prince William County (“circuit court”) on: one count of

robbery, in violation of Code § 18.2-58; one count of use or display of a firearm in the

commission of a robbery, in violation of Code § 18.2-53.1; one count of abduction, in violation

of Code § 18.2-47; and three counts of grand larceny, in violation of Code § 18.2-95. Following

a bench trial, Robinson was convicted of robbery, use or display of a firearm in the commission

of a robbery, abduction, and one count of grand larceny. The circuit court subsequently

sentenced Robinson to a total of sixty-five years’ imprisonment, with forty-four years and three

months suspended. On appeal, Robinson argues that the circuit court erred in denying his

motion to sever the three counts of grand larceny from the other offenses. I. BACKGROUND

On November 7, 2016, a grand jury indicted Robinson on three counts of grand larceny

arising from one theft of a television from Sam’s Club on April 5, 2016, and two thefts of

televisions from H.H. Gregg and the same Sam’s Club on April 14, 2016. The grand jury also

indicted Robinson on one count of robbery, use or display of a firearm in the commission of a

robbery, and abduction arising out of incidents that occurred at a Shell gas station on April 15,

2016.

On July 30, 2018, the circuit court was scheduled to hold a jury trial. Prior to the start of

the trial, the Commonwealth Attorney noted that there was an outstanding motion to sever the

offenses and hold separate trials. Robinson’s counsel responded that Robinson “wants to sever

the grand larcenies from . . . the robbery charge.” As the circuit court tried to obtain a written

copy of the motion, Robinson told the circuit court, “I’ve written to Ms. Jacqueline, the Clerk of

Circuit Court to ask for those, ask for some motions, so that’s probably what you might be

looking at.”

After briefly conferring with his counsel, Robinson agreed to waive his right to a jury

trial, and, with the Commonwealth’s consent, the circuit court released the jury. The circuit

court asked defense counsel, “[t]hen does that take care of the issue you were having with regard

to severing since we do not have a jury?” Defense counsel replied, “I think so, Judge. We’re

ready to proceed.” The circuit court arraigned Robinson and took a recess for lunch.

Following the recess, defense counsel stated, “Judge my client is renewing the motion to

separate these cases and I think that him and I might be at an impasse in going forward in this

circumstance. I don’t think that’s what we should do, but I’m just relaying to you what he’s

asking to do here.” After the Commonwealth proffered a link between the two sets of offenses,

the circuit court denied the motion to sever. The circuit court subsequently found Robinson

-2- guilty of robbery, use or display of a firearm in the commission of a robbery, abduction, and one

count of grand larceny. This appeal follows.

II. ANALYSIS

Standard of Review

“The question whether an accused, pursuant to Rule 3A:10(c), can be tried in a single

trial for all offenses then pending against that defendant is a matter resting within a [circuit]

court’s sound discretion.” Cousett v. Commonwealth, 71 Va. App. 49, 57 (2019) (quoting

Commonwealth v. Minor, 267 Va. 166, 172 (2004)). “Accordingly, ‘[t]he circuit court’s

decision to join offenses for trial is reviewed for abuse of discretion.’” Id. (alteration in original)

(quoting Walker v. Commonwealth, 289 Va. 410, 415 (2015)). “A [circuit] court’s interpretation

and application of the Rules of the Supreme Court, however, presents a question of law that we

review de novo.” Id. However, before we can reach the issue of whether the circuit court erred

in joining these offenses in a single trial, we must address whether the issue was properly before

that Court and thus properly before us.

Whether the Motion to Sever was Properly Made

Under our Anglo-American justice system of adversarial advocacy, certain fundamental

matters must be the exclusive, but informed, decision of the defendant in a criminal case—the

nature of the plea to be entered, whether to waive jury trial, whether to testify—and whether to

waive certain constitutional guarantees such as the right to counsel. See Florida v. Nixon, 543

U.S. 175, 187 (2004). Other strategic and tactical decisions associated with representation,

however, are the province and the ultimate responsibility of the attorney. Florida v. Nixon, 543

U.S. 175, 187 (2004); Va. Rules of Professional Conduct, Rule 1.2(a). “An attorney

undoubtedly has a duty to consult with the client regarding ‘important decisions,’ including

questions of overarching defense strategy.” Id. (quoting Strickland v. Washington, 466 U.S. 668,

-3- 688 (1984)). “That obligation, however, does not require counsel to obtain the defendant’s

consent to ‘every tactical decision.’” Id. (quoting Taylor v. Illinois, 484 U.S. 400, 417-18

(1988)); see also Va. Rules of Professional Conduct, Rule 1.2(a) (explaining that after the lawyer

consults with the client as to the means to be used to achieve the client’s objectives, “a lawyer is

not required to . . . employ means simply because a client may wish that the lawyer do so”).

“[T]he lawyer has—and must have—full authority to manage the conduct of the trial.” Taylor,

484 U.S. at 418. “The adversary process could not function effectively if every tactical decision

required client approval.” Id.

Whether to file a motion to sever offenses is a classic pre-trial tactical decision, at the

core of managing the conduct of the trial, that must be left to the discretion of the lawyer if a

defendant is not acting pro se.1 Allowing a represented defendant to independently file tactical

motions such as a motion to sever would potentially undermine his counsel’s trial strategy and

tactics, and places the trial courts and the prosecution in the position of not knowing who is

actually conducting the defense. The resulting confusion places an undue burden on the

defendant’s counsel and interferes with counsel’s ability and obligation to effectively represent

his client, though it does not clearly waive that obligation. Permitting preventable confusion in

the adversary process undermines effective advocacy by the parties involved as well as

administration of justice by the courts.

If a motion to sever the offenses is not made “with reasonable certainty at the time of the

ruling, except for good cause shown or to enable the Court of Appeals to attain the ends of

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Taylor v. Illinois
484 U.S. 400 (Supreme Court, 1988)
Florida v. Nixon
543 U.S. 175 (Supreme Court, 2004)
Commonwealth v. Minor
591 S.E.2d 61 (Supreme Court of Virginia, 2004)
Nelson v. State
691 S.E.2d 363 (Court of Appeals of Georgia, 2010)

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William Howard Robinson v. Commonwealth of Virginia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-howard-robinson-v-commonwealth-of-virginia-vactapp-2020.