William O. Flannagan, Jr. v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedAugust 16, 2022
Docket0923212
StatusPublished

This text of William O. Flannagan, Jr. v. Commonwealth of Virginia (William O. Flannagan, 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
William O. Flannagan, Jr. v. Commonwealth of Virginia, (Va. Ct. App. 2022).

Opinion

COURT OF APPEALS OF VIRGINIA PUBLISHED

Present: Judges AtLee, Causey and Senior Judge Haley Argued by videoconference

WILLIAM O. FLANNAGAN, JR. OPINION BY v. Record No. 0923-21-2 JUDGE RICHARD Y. ATLEE, JR. AUGUST 16, 2022 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF LOUISA COUNTY Timothy K. Sanner, Judge

Ryan J. Rakness (Rakness & Wright PLC, on brief), for appellant.

Matthew P. Dullaghan, Senior Assistant Attorney General (Jason S. Miyares, Attorney General, on brief), for appellee.

After a jury trial, the Circuit Court of Louisa County (“trial court”) convicted appellant

William O. Flannagan, Jr. of first-degree murder, in violation of Code § 18.2-32, and use of a

firearm in the commission of a murder, in violation of Code § 18.2-53.1. On appeal, Flannagan

argues that the trial court erred by “excluding defense evidence of a preliminary breath test

conducted on [Flannagan] and testimony as to his intoxication based on that evidence.” Because

we find that Flannagan’s proffer was insufficient to establish the reliability of the preliminary

breath test machine, we affirm the decision of the trial court.

I. BACKGROUND

“Under well-settled principles of appellate review, we consider the evidence presented at

trial in the light most favorable to the Commonwealth, the prevailing party below.” Vay v.

Commonwealth, 67 Va. App. 236, 242 (2017) (quoting Smallwood v. Commonwealth, 278 Va. 625,

629 (2009)). “This principle requires us to ‘discard the evidence of the accused in conflict with that

of the Commonwealth, and regard as true all the credible evidence favorable to the Commonwealth and all fair inferences to be drawn therefrom.’” Id. (quoting Parks v. Commonwealth, 221 Va. 492,

498 (1980)).

On July 3, 2019, Flannagan and Jason Ferguson attended a gathering in Devin Speh’s

garage. Flannagan had been drinking throughout the afternoon. Despite being friends,

Flannagan and Ferguson argued several times throughout the evening. During the first

argument, Flannagan pulled out a gun he had brought and “cocked the hammer back.” In

between arguing, Flannagan continued drinking.

During the final argument that evening, Flannagan pulled the gun out again, and he was

waving it around. Because of the argument and the gun, the other people present felt

uncomfortable and decided to leave. Speh told Flannagan and Ferguson it was “time to go.”

Speh was rolling up an extension cord when he heard a gunshot. He turned around; Speh saw

Ferguson slump back into the chair. Flannagan was standing a few feet away from Ferguson

with the gun in his hand pointed downward towards Ferguson. Speh ran into the home, locked

the doors, and called 911. Flannagan left on foot. Ferguson died from the gunshot wound.

Officers dispatched to the scene saw an individual matching the suspect’s description

walking along the edge of the road. The officers observed the individual throw something,

which turned out to be the gun used to shoot Ferguson. The officers arrested the individual, later

identified as Flannagan. Flannagan was indicted for first-degree murder.

During his trial, Flannagan sought to elicit testimony about a preliminary breath test

(“PBT”)1 that officers conducted when they arrested Flannagan. The Commonwealth objected to

the relevance and admissibility. Flannagan explained that he intended to introduce the results of

1 A preliminary breath test “determine[s] the probable alcoholic content” of a person’s blood. Code § 18.2-267(A). -2- the PBT and have an expert testify about what that level of intoxication would indicate. This

evidence was intended to challenge the premeditation element of the first-degree murder charge.

Flannagan explained that the officer that administered the test was prepared to testify that

he had calibrated the PBT device five days before it was used on Flannagan. Flannagan also had

the device’s calibration logs. The trial court asked how that “establish[ed] the reliability of the

test overall.” Flannagan used Santen v. Tuthill, 265 Va. 492 (2003), and a 2013 Attorney

General opinion to argue that the PBT results were admissible if there was evidence the device

was properly calibrated.

The trial court asked if Flannagan’s expert would testify that the PBT device was

“reliable and that she can rely upon that in her field to render an opinion as to the blood alcohol

content at the time of the reading.” Flannagan indicated that he thought the expert would testify

to that, but the Commonwealth “d[id] not believe that to be the case.” The trial court explained

that if the expert could testify the PBT is “reliable for establishing the blood alcohol content at

that time,” then the PBT results would be admissible, but if the expert could not, then the results

were not admissible.

The trial court took a brief recess to allow Flannagan to check with the expert. When

Flannagan returned, he reported that the expert could not opine on the reliability of the PBT

device. The trial court explained that there were two types of tests; the test after arrest, which is

admissible as evidence, and the preliminary test, like here, used by officers to establish probable

cause. To admit the preliminary test results, a party must establish reliability, and if a party does

not do so, the trial court cannot admit the results into evidence. Because Flannagan was unable

to establish reliability, the trial court sustained the Commonwealth’s objection.

The trial court allowed Flannagan to make a proffer to preserve the record. Flannagan

proffered that the officer would testify that the device used was properly calibrated and that he

-3- administered that test in accordance with his training. Flannagan argued that this should be

sufficient under Santen v. Tuthill. He also proffered that if the results were admitted, the expert

would testify what a blood alcohol content of .189, which was Flannagan’s result, meant and

how it would affect “judgment, attention, motor coordination, and reaction time.”

Ultimately, the jury found Flannagan guilty of both first-degree murder and use of a

firearm while committing murder. Flannagan now appeals his convictions to this Court.

II. ANALYSIS

A. Standard of Review

“[W]e review a trial court’s decision to admit or exclude evidence using an abuse of

discretion standard and, on appeal, will not disturb a trial court’s decision to admit evidence

absent a finding of abuse of that discretion.” Kenner v. Commonwealth, 299 Va. 414, 423 (2021)

(alteration in original) (quoting Avent v. Commonwealth, 279 Va. 175, 197 (2010)). “In

evaluating whether a trial court abused its discretion, . . . we do not substitute our judgment for

that of the trial court. Rather, we consider only whether the record fairly supports the trial

court’s action.” Id. (alteration in original) (quoting Carter v. Commonwealth, 293 Va. 537, 543

(2017)).

-4- B. Preliminary Breath Tests

Flannagan argues that the trial court erred by refusing to admit the PBT results. He

argues that the PBT was sufficiently reliable2 to admit the results because he proffered evidence

that the device was recently calibrated.3 We disagree.

Code § 18.2-267 regulates the use of PBTs in certain types of alcohol-related offenses.

Code § 18.2-267(D) provides that the results of a PBT can be used to form the basis of probable

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Related

Avent v. Com.
688 S.E.2d 244 (Supreme Court of Virginia, 2010)
Smallwood v. Com.
688 S.E.2d 154 (Supreme Court of Virginia, 2009)
Billips v. Com.
652 S.E.2d 99 (Supreme Court of Virginia, 2007)
Santen v. Tuthill
578 S.E.2d 788 (Supreme Court of Virginia, 2003)
Richard Alvin Otey v. Commonwealth of Virginia
735 S.E.2d 255 (Court of Appeals of Virginia, 2012)
Hall v. Commonwealth
529 S.E.2d 829 (Court of Appeals of Virginia, 2000)
Stacy v. Commonwealth
470 S.E.2d 584 (Court of Appeals of Virginia, 1996)
Spencer v. Commonwealth
393 S.E.2d 609 (Supreme Court of Virginia, 1990)
Parks v. Commonwealth
270 S.E.2d 755 (Supreme Court of Virginia, 1980)
Manneh Vay v. Commonwealth of Virginia
795 S.E.2d 495 (Court of Appeals of Virginia, 2017)
Carter v. Commonwealth
800 S.E.2d 498 (Supreme Court of Virginia, 2017)

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William O. Flannagan, Jr. v. Commonwealth of Virginia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-o-flannagan-jr-v-commonwealth-of-virginia-vactapp-2022.