Hilton v. Commonwealth, 797 S.E.2d 781

Tavon Hilton (d/b/a "James") arranged a meeting to sell a car; Ronald and Rodney Wetzler went to meet him in Ronald’s pickup truck.
At the meeting Hilton (with an accomplice) produced a revolver, pointed it at Ronald, and threatened him; the accomplice took cash and keys.
Hilton ordered Ronald and Rodney into Ronald’s truck and began to walk away while still holding the truck keys (the accomplice had physically taken the keys).
Ronald retrieved a shotgun moments later, fired a warning shot; Hilton fired rounds at Rodney during Rodney’s pursuit; both assailants fled.
Hilton was tried and convicted of carjacking (Va. Code § 18.2-58.1), use of a firearm in the commission of carjacking (Va. Code § 18.2-53.1), and related offenses; he appealed on sufficiency and jury-instruction grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for carjacking and related firearm enhancement	Commonwealth: evidence (taking keys at gunpoint while victim beside truck) sufficed to show seizure or seizure of control of vehicle	Hilton: taking keys alone (victim remained beside truck, regained access to shotgun, no entry into truck) insufficient to prove loss of possession/control	Court: Affirmed — taking keys at gunpoint while victim was next to truck and forced back into truck was enough for a rational juror to find temporary seizure/control and satisfy carjacking elements
Denial of Hilton's proffered jury instruction (limiting weight of key-taking)	Hilton: jury should be instructed that taking keys alone cannot establish carjacking; keys are only evidence of intent to control	Commonwealth: model carjacking instruction adequately states elements and lets jurors assess facts; special instruction would single out evidence	Court: Affirmed — model instruction ‘‘fully and fairly’’ covered the law; proffered instruction improperly singled out part of the evidence and was unnecessary

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
Pressley v. Commonwealth, 54 Va. App. 380 (Va. Ct. App. 2009) (taking keys from victim upheld as seizure of vehicle control)
Grimes v. Commonwealth, 288 Va. 314 (statutory interpretation and ordinary-meaning approach)
Bowman v. Commonwealth, 290 Va. 492 (high degree of appellate deference in sufficiency review)
Daniels v. Commonwealth, 275 Va. 460 (trial court discretion on jury instructions; no abuse when model instruction fully covers law)