History
  • No items yet
midpage
Derrick Dominique Robinson v. Commonwealth of Virginia
0066242
Va. Ct. App.
May 20, 2025
Read the full case

Background

  • Derrick Dominique Robinson was convicted in Virginia state court for multiple drug distribution and firearm offenses after a jury trial.
  • The police used a confidential informant (Sample) to make four controlled drug buys from Robinson, with each transaction closely monitored and recorded by police.
  • Following the fourth controlled buy, a search of Robinson’s residence and vehicle yielded cocaine, marijuana, cash (including marked bills from a controlled buy), drug packaging equipment, and three handguns.
  • At trial, Robinson denied distributing drugs to Sample and claimed alternative explanations for the presence of contraband and firearms.
  • After trial, Robinson discovered the informant had a prior misdemeanor conviction for possessing forged bank notes and moved for a new trial on that basis, arguing it was crucial impeachment evidence.
  • The trial court denied the motion for new trial and affirmed the convictions, finding the evidence against Robinson overwhelming and the impeachment material minimal.

Issues

Issue Robinson's Argument Commonwealth's Argument Held
Sufficiency of evidence—drug distribution convictions No direct video of hand-to-hand drug transactions; possible informant deceit Circumstantial evidence and police surveillance made distribution only plausible explanation Sufficient evidence supported convictions
Sufficiency of evidence—constructive possession (residence/vehicle) Simply living at the residence or owning the car doesn't prove knowing possession Combined circumstantial evidence established dominion, control, and knowledge Argument for these charges not properly raised/preserved on appeal
New trial based on after-discovered impeachment evidence Impeachment of key informant would have affected credibility and outcome Prior conviction for informant would have little impact given corroborating police evidence No abuse of discretion in denying new trial
Preservation of sufficiency arguments (Rule 5A:18) General motions to strike preserved sufficiency arguments Lack of specificity failed to preserve issues about possession in residence/vehicle Defendant failed to preserve sufficiency issues for appeal

Key Cases Cited

  • Stamper v. Commonwealth, 220 Va. 260 (circumstantial evidence may suffice to prove guilt)
  • Pijor v. Commonwealth, 294 Va. 502 (circumstantial evidence must exclude every reasonable hypothesis except guilt)
  • Burchette v. Commonwealth, 15 Va. App. 432 (occupancy plus circumstantial evidence may support constructive possession)
  • Avent v. Commonwealth, 279 Va. 175 (standards for granting new trials based on after-discovered evidence)
  • Orndorff v. Commonwealth, 271 Va. 486 (four-part test for after-discovered evidence motions)
  • Mundy v. Commonwealth, 11 Va. App. 461 (impeachment evidence alone generally does not justify new trial)
Read the full case

Case Details

Case Name: Derrick Dominique Robinson v. Commonwealth of Virginia
Court Name: Court of Appeals of Virginia
Date Published: May 20, 2025
Docket Number: 0066242
Court Abbreviation: Va. Ct. App.