George Wesley Huguely, V v. Commonwealth of Virginia
63 Va. App. 92
| Va. Ct. App. | 2014Background
- Huguely was convicted in Charlottesville of second-degree murder and grand larceny; on appeal challenges only the murder conviction.
- May 2–3, 2010: Huguely allegedly attacked Yeardley Love at her Charlottesville apartment; death attributed to blunt force head injury.
- Huguely had two privately retained lawyers; illness of one counsel led to temporary courtroom absence and scheduling concerns.
- Voir dire spanned three days; questionnaire addressed media exposure and potential biases; jury ultimately seated after lengthy trial.
- Defense argued denial of a continuance and limitations on voir dire affected his Sixth Amendment right to counsel and a fair jury; trial court rejected these claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to counsel; denial of continuance | Huguely asserts denial of his chosen counsel violated Sixth Amendment and Gonzalez-Lopez. | Court acted within discretion; no structural error; continuances are disfavored absent compelling reasons. | No reversible error; no new trial required. |
| Voir dire about blaming the victim | Defense should be allowed to ask if jurors would view blaming the victim as improper; relevance under Code 8.01-358. | Question not required; not tied to the four Code factors; not helpful or properly framed. | Question not required; no reversible error. |
| Motions to strike for cause | Several jurors should have been struck for bias or impartiality. | Trial court’s seating of jurors was within broad discretion and not manifest error. | No abuse of discretion; no reversible error in denying strike-for-cause motions. |
| Malice jury instruction | Probative malice language should have been included to reflect broader concept of malice. | Commonwealth’s Model Instruction No. 33.220 is proper; proposed expansion duplicative. | No abuse of discretion; trial court properly declined duplicate instruction. |
Key Cases Cited
- Gonzalez-Lopez v. United States, 546 U.S. 140 (U.S. 2006) (retained counsel of choice; structural error framework)
- Morris v. Slappy, 461 U.S. 1 (U.S. 1983) (continuance discretion; scheduling deference)
- Johnson v. Commonwealth, 51 Va. App. 369 (Va. Ct. App. 2008) (abuse of discretion standard for continuances)
- Briley v. Commonwealth, 222 Va. 180 (Va. 1981) (media exposure and juror impartiality; Briley principles)
- LeVasseur v. Commonwealth, 225 Va. 564 (Va. 1983) (voir dire; limits on questions; discretion of court)
- Justus v. Commonwealth, 220 Va. 971 (Va. 1980) (impartiality standard; voir dire sufficiency)
- Weeks v. Commonwealth, 248 Va. 460 (Va. 1994) (contextual evaluation of equivocal juror responses)
- Chapman v. Commonwealth, 56 Va. App. 725 (Va. Ct. App. 2010) (standard for evaluating jury instruction error)
- Thomas v. Commonwealth, 279 Va. 131 (Va. 2010) (malice instruction model; Virginia authority)