Lovos-Rivas v. Commonwealth, 707 S.E.2d 27

Lovos-Rivas was convicted of forcible sodomy under Code § 18.2-67.1 and aggravated sexual battery under Code § 18.2-67.3.
Voir dire began with jurors indicating no personal interest, information, or bias; one juror was excused.
Prosecutor asked about past sexual assault experiences; some jurors were stricken for cause, others remained.
Defense questioned jurors on credibility biases concerning child testimony; several jurors indicated potential bias.
Appellant moved to strike nearly all remaining venire except seven identified juror numbers; trial court denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred in denying strike-for-cause of most venire	Lovos-Rivas argues the venire had bias toward child testimony	Lovos-Rivas asserts most venire were not impartial	No manifest error; trial court properly retained venire and affirmed conviction

Mullis v. Commonwealth, 3 Va.App. 564 (1987) (abstract questions do not prove bias; lacks fixed opinion of guilt)
Justus v. Commonwealth, 220 Va. 971 (1980) (impartiality requires ability to render verdict based on law and evidence)
Spangler v. Ashwell, 116 Va. 992 (1914) (juror not indifferent may be excluded; standard for impartiality)
Briley v. Commonwealth, 222 Va. 180 (1981) (whether voir dire reveals casual impressions vs. deep convictions)
Mullis v. Commonwealth, 3 Va.App. 564 (1987) (purpose of abstract propositions; cannot show fixed bias)
Townsend v. Commonwealth, 270 Va. 325 (2005) (trial court in superior position to judge venire fairness)
Juniper v. Commonwealth, 271 Va. 362 (2006) (whole voir dire must be considered; not isolated portions)
Barrett v. Commonwealth, 262 Va. 823 (2001) (manifest error standard for trial court decisions on voir dire)