Michael Ray Jennings v. Commonwealth of Virginia
1625151
| Va. Ct. App. | Oct 18, 2016Background
- Goode lived with her four daughters; youngest child fathered by Jennings.
- Jennings moved out in April 2014 after relationship ended; Goode terminated contact January 31, 2015 and she was assaulted.
- On February 1, 2015, Jennings unlawfully entered Goode’s unlit home by forcing the bedroom window air-conditioner unit out.
- Goode awoke to Jennings in the girls’ bedroom; he claimed he wanted to hug his daughter; Goode told him to leave.
- Jennings fled with Goode’s phone after snatching it from its charger; Goode and children fled the home fearing for safety.
- Appellant was convicted under Code § 18.2-121; evidence supported that he intended to interfere with Goode’s use and enjoyment of her home.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence proves intent to interfere with occupancy rights | Commonwealth argues intent inferred from entry. | Jennings argues an innocent hypothesis: hugging daughter. | Yes; evidence supports intent to interfere beyond reasonable doubt. |
Key Cases Cited
- Wood v. Commonwealth, 57 Va. App. 286 (2010) (defer to trial court on sufficiency; affirm if evidence supports guilt beyond reasonable doubt)
- Vasquez v. Commonwealth, 291 Va. 232 (2016) (discusses reasonable-hypothesis principle in sufficiency review)
- Sandoval v. Commonwealth, 20 Va. App. 133 (1995) (presumption of unlawful purpose from unlawful entry)
- Kyer v. Commonwealth, 45 Va. App. 473 (2005) (privacy interest in home; standard for interference)