Hylton v. Commonwealth
60 Va. App. 50
Va. Ct. App.2012Background
- Hylton illegally possessed methadone, brought it home, and left a cup containing it unattended on the kitchen counter.
- Trevor, aged 3, ingested the methadone and died; autopsy showed methadone could be lethal to an adult.
- Hylton discussed shortages of methadone with her boyfriend and did not immediately seek hospital care.
- Neighbors observed Trevor's deteriorating condition; Hylton declined hospital transport due to fear of consequences and a protective order.
- Police and medical personnel later found Trevor in distress; Hylton admitted drug abuse and failure to obtain timely treatment for Trevor.
- Trial court instructed on two felony-murder theories: felonious possession and felonious abuse/neglect; verdict did not specify which theory was proven.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Trevor’s death was within the res gestae of felonious possession | Hylton’s possession continued through ingestion by Trevor | Trevor’s death occurred after possession ended | Yes; death within res gestae of possession |
| Whether Trevor’s death was within the res gestae of felonious abuse/neglect | Death tied to abuse/neglect theory | Evidence insufficient to connect to abuse/neglect | Not reached on this record (sufficiency established via possession) |
| Whether the evidence suffices to prove felony murder beyond a reasonable doubt | Evidence shows causal link between methadone possession and death | Causation not sufficiently shown | Evidence sufficient to sustain felony-murder conviction |
Key Cases Cited
- Heacock v. Commonwealth, 228 Va. 397 (1984) (felony-murder applies when a controlled substance is distributed in violation of law)
- Cotton v. Commonwealth, 35 Va.App. 511 (2001) (res gestae requires time/place/causal connection to be part of same criminal enterprise)
- King v. Commonwealth, 6 Va. App. 351 (1988) (death from circumstances coincident to felony not excluded from felony murder)
- Haskell v. Commonwealth, 218 Va. 1033 (1978) (death must be tied to the felony in a close temporal and causal sense)
- Davis v. Commonwealth, 39 Va.App. 96 (2002) (standard of review for sufficiency on appeal; defer to fact-finder)
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard: any rational trier of fact could find elements beyond reasonable doubt)