Daniel Keon Woody v. Commonwealth of Virginia, 1282223

After a family cookout where both drank, Woody and his then-girlfriend Atia Austin argued at Woody’s home; Woody spat on Austin and told her to leave.
Austin testified Woody pushed her to the ground and pinned her in the laundry room; her 10‑year‑old son D.A. came to help and Woody bit D.A.’s forearm, causing bleeding.
Austin testified Woody also bit her thigh multiple times; nursing photographs documented ten significant injuries to Austin and a bite mark on D.A.’s arm.
Woody testified he was attacked by Austin and others, bit D.A. only in self‑defense, and denied biting Austin; police observed Woody intoxicated and agitated and he admitted biting the child.
The trial court convicted Woody of assault and battery of Austin and unlawful wounding of D.A., found reasonable doubt as to whether Woody had bitten Austin’s thigh, and rejected Woody’s self‑defense claim.
Woody appealed, arguing the court erred in rejecting his self‑defense defense and that the court’s lack of explicit demeanor findings showed arbitrary credibility determinations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred in rejecting Woody’s self‑defense claim (assault & battery of Austin; unlawful wounding of D.A.)	Commonwealth: testimony and physical evidence corroborate victims and support convictions	Woody: his trial testimony (and physical evidence) proves he acted in self‑defense; convictions should be vacated	Affirmed. Trial court credited victim testimony; appellate court defers to factfinder on credibility and finds evidence sufficient
Whether the evidence proved the requisite intent/malice for unlawful wounding	Commonwealth: evidence (bite causing bleeding, injuries) supports unlawful wounding conviction	Woody: lacked intent to maim/disfigure/disable or actual malice; was defending himself	Affirmed. Court concluded testimony and physical evidence supported conviction for unlawful wounding of D.A.
Whether trial court was required to make explicit factual findings about witness demeanor/credibility	Commonwealth: no obligation to detail reasoning; presumption court resolved factual disputes for prevailing party	Woody: absence of explicit credibility findings suggests arbitrary rejection of his testimony	Rejected. Trial courts need not give detailed findings; appellate court presumes proper application of law and defers to factfinder

Commonwealth v. Cady, 300 Va. 325 (articulating the "light most favorable to the Commonwealth" standard on appeal)
Commonwealth v. Perkins, 295 Va. 323 (same appellate evidentiary framing)
Ragsdale v. Commonwealth, 38 Va. App. 421 (witness testimony disturbed on appeal only if inherently incredible)
Gerald v. Commonwealth, 295 Va. 469 (defines when evidence is "incredible")
Juniper v. Commonwealth, 271 Va. 362 (clarifies the "incredible" evidence standard)
Commonwealth v. McNeal, 282 Va. 16 (factfinder may choose between competing witness accounts)
Bazemore v. Commonwealth, 42 Va. App. 203 (factfinder may believe part of a witness’s testimony and disbelieve other parts)
Pilati v. Pilati, 59 Va. App. 176 (trial court not required to give detailed findings of fact and conclusions of law)
Smith v. Commonwealth, 56 Va. App. 711 (no appellate relief when factfinder bases verdict on parts of testimony sufficient to support it)
Dalton v. Commonwealth, 64 Va. App. 512 (credibility determinations are within the exclusive province of the factfinder)