Boone v. Commonwealth, 740 S.E.2d 11

Boone was indicted for possession of a firearm after prior violent felony convictions under Code § 18.2-308.2(A).
The Commonwealth offered five prior convictions: one robbery and four burglaries, all violent felonies.
Boone objected that the statute allows evidence of only one prior violent felony; admitting all five was prejudicial and cumulative.
Circuit court admitted all five convictions; Boone was found guilty and sentenced to five years.
Court of Appeals affirmed by unpublished per curiam order; Boone appealed to Virginia Supreme Court.
Issue presented: whether § 18.2-308.2(A) limits the Commonwealth’s evidentiary proof of prior violent felonies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 18.2-308.2(A) limits evidence to one prior violent felony	Boone: limit to one violent felony; other convictions cumulative	Commonwealth: may prove all relevant convictions to meet burden	Statute does not limit; admissible to prove all convictions

Pittman v. Commonwealth, 17 Va. App. 33 (Va. Ct. App. 1993) (Commonwealth may prove all relevant evidence to meet burden)
Conley v. Commonwealth, 284 Va. 691 (Va. 2012) (vacatur proceedings may affect validity of convictions; preserve record)
Rushing v. Commonwealth, 284 Va. 270 (Va. 2012) (vacation of convictions may affect sufficiency of evidence)
Old Chief v. United States, 519 U.S. 172 (Supreme Court 1997) (stipsulation of prior conviction; probative value vs prejudice)
Glover v. Commonwealth, 3 Va. App. 152 (Va. Ct. App. 1986) (whether defendant may stipulate to fact of conviction; limitations)
Harrison v. Commonwealth, 244 Va. 576 (Va. 1992) (trial court discretion to exclude cumulative prejudicial evidence)
Juniper v. Commonwealth, 271 Va. 362 (Va. 2006) (evidentiary balancing; probative value vs prejudice)