James Donta Whitfield v. Commonwealth of Virginia, 0333161

Whitfield drove a Buick LeSabre that struck a Nissan Altima on I-264; he left the scene and stopped about 0.2 mile down an exit ramp.
Independent witness Crist and officers described significant visible damage to the Altima (front end pushed, bumper gone, airbags deployed) and to Whitfield’s car (rear/side damage, wheel/rim damage, sparks while driving).
No occupant of the Altima testified; Commonwealth introduced three photos of Whitfield’s LeSabre but no repair estimates, invoices, pre-crash vehicle values, model years, or mileage.
The trial court sustained objections to testimony estimating dollar value of damage and declined to qualify the trooper as an expert on damage valuation.
Despite excluding dollar estimates, the trial court found circumstantially that combined vehicle damage exceeded $1,000 and convicted Whitfield of felony hit-and-run; Whitfield appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Commonwealth proved damage > $1,000 to elevate hit-and-run to a felony	Commonwealth: circumstantial proof (photos, descriptions, airbags, inoperability, visible damage) supports a finding > $1,000	Whitfield: no admissible evidence of dollar value, pre-crash condition, repairs, or vehicle values — conviction would rest on speculation	Reversed: evidence insufficient and trial court’s valuation was speculative and internally inconsistent

Wright v. Commonwealth, 196 Va. 132, 82 S.E.2d 603 (establishes that when value determines grade of offense, Commonwealth must prove statutory value)
Dunn v. Commonwealth, 222 Va. 704, 284 S.E.2d 792 (reversal where jury’s finding of value was based on speculation)
Hayden v. Commonwealth, 203 Va. 398, 124 S.E.2d 13 (circumstantial evidence may prove guilt)
Littlejohn v. Commonwealth, 24 Va. App. 401, 482 S.E.2d 853 (conviction cannot rest on conjecture)
Kelley v. Commonwealth, 289 Va. 463, 771 S.E.2d 672 (standard for viewing conflicting evidence on appeal)