Burkeen v. Commonwealth, 286 Va. 255

Burkeen confronted Mayer outside a bar, demanding to buy Mayer's pool cue for $200 after learning its price.
Mayer refused; Burkeen punched Mayer in the face and then taunted him about the sale and his strength.
Burkeen then assaulted Keith Taylor, striking him multiple times after Taylor tried to shield Mayer.
Mayer sustained significant facial fractures requiring major reconstructive surgery and ongoing headaches and scarring.
Burkeen bragged about his strength and continued, pausing only when police were mentioned; Taylor was attacked next.
The circuit court convicted Burkeen of malicious wounding under Code § 18.2-51; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a single bare-fist blow can prove intent to maim	Burkeen: single blow cannot convict for intent	Commonwealth: circumstances show intent to maim despite one blow	Affirmed; single blow may support intent to maim under circumstances

Dawkins v. Commonwealth, 186 Va. 55 (1947) (malice may be inferred from acts or conduct)
Roark v. Commonwealth, 182 Va. 244 (1944) (bare fist attack may lack intent to injure)
Shackelford v. Commonwealth, 183 Va. 423 (1945) (extreme brutality supports intent to maim)
Fletcher v. Commonwealth, 209 Va. 636 (1969) (violence and brutality can prove intent to maim)
Johnson v. Commonwealth, 53 Va. App. 79 (2008) (single bare-fist blow may support intent under certain circumstances)
Dowdy v. Commonwealth, 220 Va. 114 (1979) (elemental proof beyond reasonable doubt required)
Banovitch v. Commonwealth, 196 Va. 210 (1954) (intent to maliciously wound evidenced by words or conduct)
Clark v. Commonwealth, 279 Va. 636 (2010) (standard of review for sufficiency of evidence)