Andrew Nicholas Chavis v. Commonwealth of Virginia, 1029162

Andrew N. Chavis was convicted after a bench trial of involuntary manslaughter under Va. Code § 18.2-36.1(A) for a fatal rear-end collision that killed two occupants of another vehicle.
Crash facts: on I-64 at ~8:00 p.m., the Nissan driven by Sheila McCowan was struck from behind, pushed into the woods and a tree; extensive rear damage to the Nissan and front damage to Chavis’s 2011 Hyundai Sonata. Two passengers died at the scene.
Evidence of intoxication: Chavis admitted drinking two large margaritas; blood draws showed BAC .13–.14% (9:30 p.m.) and .132% (12:20 a.m.); expert retrograde extrapolation placed BAC at collision time between .145 and .172%.
Event Data Recorder (EDR) from Chavis’s Hyundai was downloaded by an expert (Richard Ruth). The EDR showed a large delta-v and indicated very high pre-impact speed (121–122 mph), but testimony about exact speed was limited because of uncertainties (tire size) and the trial court excluded any conclusive speed finding by the expert.
Trial court found that intoxication impaired Chavis’s judgment and control, that he was driving at high speed, failed to appreciate the slower vehicle changing lanes, and caused the fatal collision; court relied on toxicology, eyewitness account, vehicle damage photos, and limited EDR-derived data.

Issue	Plaintiff's Argument (Commonwealth)	Defendant's Argument (Chavis)	Held
Admissibility of EDR expert testimony	Ruth may explain EDR data to aid the trier of fact	Ruth impermissibly interpreted EDR data and invaded the factfinder’s role	Trial court did not abuse discretion; Ruth limited to EDR data and did not opine on ultimate speed
Sufficiency: causal link between intoxication and deaths	Intoxication (high BAC) impaired driving; circumstantial evidence (rear damage, witness account, EDR delta-v) supports causation	Evidence is circumstantial and insufficient to prove intoxication caused the crash	Evidence sufficient; a rational factfinder could find intoxication caused the collision and deaths

Midkiff v. Commonwealth, 280 Va. 216 (2010) (abuse-of-discretion standard for evidentiary rulings)
Velazquez v. Commonwealth, 263 Va. 95 (2002) (expert testimony permitted to assist trier of fact)
Grasty v. Tanner, 206 Va. 723 (1965) (limits on expert accident-reconstruction testimony to avoid invading factfinder’s province)
Wyatt v. Commonwealth, 47 Va. App. 411 (2006) (involuntary manslaughter under § 18.2-36.1(A) requires proof of DUI and causal connection)
Goodman v. Commonwealth, 37 Va. App. 374 (2001) (same principle: must show intoxication caused death)
Kelly v. Commonwealth, 41 Va. App. 250 (2003) (presumption of correctness for trial court’s factual findings on appeal)
Williams v. Commonwealth, 278 Va. 190 (2009) (Jackson standard for sufficiency review)
Jackson v. Virginia, 433 U.S. 307 (1979) (standard: whether any rational trier of fact could find guilt beyond reasonable doubt)
Commonwealth v. Smith, 259 Va. 780 (2000) (circumstantial evidence must be consistent with guilt and inconsistent with innocence)
Commonwealth v. Hudson, 265 Va. 505 (2003) (circumstantial evidence evaluated in combination)
Muhammad v. Commonwealth, 269 Va. 451 (2005) (multiple concurrent circumstances may support conviction)