Marcus Keon Ruffin v. Commonwealth of Virginia
1815152
| Va. Ct. App. | Dec 6, 2016Background
- On April 18, 2015 Marcus Keon Ruffin and Alexis Gaitor (with whom he shares a child) argued while returning an Enterprise rental car; Gaitor exited the vehicle and Ruffin got into the driver’s seat.
- Ruffin drove from a driveway into a roundabout against the flow of traffic, passed another driver by entering the oncoming lane, and was observed driving ~60–65 mph.
- Ruffin’s car went over the roundabout median, struck an ambulance, became airborne, and rolled; the rental was totaled (stipulated value ~$16,829; damages > $18,000).
- At trial Gaitor’s testimony about Ruffin’s statements was inconsistent; she initially thought the crash was intentional but later recanted that belief.
- Ruffin argued he lacked specific intent to destroy the car and that his actions were at most negligent; the trial court found his conduct “reckless, wanton, and willful,” convicted him under Code § 18.2-137(B)(ii), and sentenced him (appeal followed).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence was sufficient to prove the specific intent required by Va. Code § 18.2-137(B) for felony destruction of property | The Commonwealth: intent may be inferred from Ruffin’s volitional, dangerous driving (speed, driving into oncoming traffic, passing, crossing the median) and his conduct and statements; those facts support an inference of intent to cause the destructive consequence. | Ruffin: he lacked the specific intent to destroy the car; his acts were negligent or mistaken (unfamiliar with the roads) and do not meet the intentional mens rea of § 18.2-137(B). | Affirmed: the trial court reasonably inferred specific intent from willful/reckless conduct; a rational factfinder could find the required intent beyond a reasonable doubt. |
Key Cases Cited
- Scott v. Commonwealth, 58 Va. App. 35, 707 S.E.2d 17 (distinguishes negligence under § 18.2-137(A) from intentionality required under § 18.2-137(B))
- Knight v. Commonwealth, 61 Va. App. 148, 733 S.E.2d 701 (upholding intent inference from extremely dangerous high-speed vehicle maneuvers)
- McDuffie v. Commonwealth, 49 Va. App. 170, 638 S.E.2d 139 (finding intent from post-altercation, high-speed driving causing a crash)
- Jackson v. Virginia, 443 U.S. 307 (sets standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)