Larry Eugene Coney, Jr. v. Commonwealth of Virginia, 0159161

On May 18, 2014, three-year-old K.B. was left in Larry Eugene Coney Jr.’s care while the child’s mother, Carrie Jones, worked; K.B. appeared normal the previous day and during a work-break phone call at 2:16 p.m.
Jones returned about 7:10 p.m. to find K.B. unresponsive, seizing, drooling, with labored breathing and in a puddle of urine; paramedics transported him to the hospital and he was later moved to CHKD.
Medical experts (Dr. Susan Lamb and Dr. Elizabeth Kinnison) testified to numerous fresh and healing blunt-force bruises, skull fractures, subdural/subarachnoid hemorrhage, retinal hemorrhage, a swollen brain, and internal injuries; cause of death: blunt force head injuries.
The trial court found the fatal injury occurred between 2:16 p.m. and 7:10 p.m., while Coney was K.B.’s sole caretaker, rejected alternative-perpetrator theories (mother and roommate), and relied on Coney’s inconsistent statements, attempts to deflect blame, expressed intent to surrender then flight, and statements to family as inculpatory.
Coney was convicted in a bench trial of second-degree murder and aggravated malicious wounding; he appealed, arguing the evidence was insufficient because others had access to K.B. and thus a reasonable hypothesis of innocence existed.

Issue	Plaintiff's Argument (Commonwealth)	Defendant's Argument (Coney)	Held
Sufficiency of evidence to prove Coney inflicted fatal injuries	Medical and circumstantial evidence, timeline, Coney’s statements and flight establish opportunity, means, and guilty knowledge	Others (mother Jones or roommate Ryales) had access during the relevant period, creating a reasonable hypothesis of innocence	Affirmed: evidence sufficient; court reasonably excluded alternative perpetrators
Whether the reasonable-hypothesis principle required reversal	Commonwealth: principle reflects beyond-a-reasonable-doubt standard and does not add a separate burden; factfinder can reject alternative hypotheses	Coney: Christian controls—if others had access, conviction cannot rest solely on custody inference	Affirmed: Christian distinguishable; here opportunity plus other incriminating circumstances exclude alternatives
Whether medical testimony permitted timing the injury to Coney’s custody	Commonwealth: doctors testified injury would produce immediate, obvious symptoms, fitting the period Coney had sole custody	Coney: expert testimony allowed injury could have occurred shortly before EMS arrival, potentially after Jones returned	Held: trial court credited that injury occurred while Coney had custody; medical testimony and observations by Jones supported that conclusion

Christian v. Commonwealth, 221 Va. 1078 (277 S.E.2d 205) (custody-alone inference insufficient where multiple known caretakers had access)
Jackson v. Virginia, 443 U.S. 307 (establishes the standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
Vasquez v. Commonwealth, 291 Va. 232 (781 S.E.2d 920) (explains reasonable-hypothesis principle mirrors burden of proof and does not add an extra requirement)
Hudson v. Commonwealth, 265 Va. 505 (578 S.E.2d 781) (framing of circumstantial-evidence and reasonable-hypothesis discussion)