Rosangela Spradling v. Commonwealth of Virginia, 2082154

Rosangela Spradling was charged with murder and related firearm offenses after shooting and killing her husband at their home on May 17, 2013; she called 911 and admitted the killing.
She pled guilty under North Carolina v. Alford to reduced counts: voluntary manslaughter, shooting in commission of a felony (with sentence suspended), and two counts of unlawfully discharging a firearm in an occupied building; no sentence agreement was made.
The plea was supported by a joint proffer that included facts the court could construe as showing premeditation and malice (multiple shots, testimony about obtaining and test-firing the gun before returning to shoot the victim).
At sentencing Spradling presented extensive mitigation: a 45-page memorandum, testimony about long-term spousal abuse, psychological evaluations diagnosing PTSD, and letters from family; she stated at allocution that she did not feel guilty.
The sentencing guidelines recommended 2 years 10 months to 6 years 10 months; the Commonwealth asked for an upward departure. The trial court imposed a total active sentence of 15 years (20 years with 5 years suspended), noting premeditation/malice and lack of remorse.

Issue	Spradling's Argument	Commonwealth's Argument	Held
Whether the trial court abused its discretion by imposing a lengthy active sentence based on facts supporting premeditation despite a manslaughter plea	The court ignored evidence of prolonged spousal abuse and mitigation and therefore imposed an unduly harsh sentence	The court reasonably considered the proffered facts (multiple shots, pre-shooting conduct) and mitigation, and stayed within the statutory range	No abuse of discretion; 15-year active sentence affirmed (within statutory maximum)
Whether Va. Code § 19.2-298.01(F) is unconstitutional insofar as it bars appellate review of sentencing departures from guidelines	The statute’s bar on appellate review violates due process by preventing review of sentencing decisions	The claim is procedurally defaulted and, in any event, irrelevant because Spradling did not challenge guideline calculation or departure rationale	Not reached on merits: claim barred by Rule 5A:18 and not implicated in this appeal; statute’s application not decided

Hancock v. Commonwealth, 12 Va. App. 774 (1991) (standard for reviewing evidence in favor of prevailing party on appeal)
Deal v. Commonwealth, 15 Va. App. 157 (1992) (trial court has wide latitude in sentencing)
Nuckoles v. Commonwealth, 12 Va. App. 1083 (1991) (deference to trial court sentencing decisions)
Scott v. Commonwealth, 58 Va. App. 35 (2011) (sentence review for abuse of discretion; within statutory range is controlling)
Martin v. Commonwealth, 274 Va. 733 (2007) (standard of appellate review of sentencing)
Jett v. Commonwealth, 34 Va. App. 252 (2001) (statutory range governs reviewability of sentence)
Abdo v. Commonwealth, 218 Va. 473 (1977) (sentence within statutory maximum will not be overturned as abuse of discretion)
Rhodes v. Commonwealth, 41 Va. App. 195 (2003) (facts in a plea proffer can support findings of premeditation and malice)
Harris v. Commonwealth, 274 Va. 409 (2007) (constitutional questions reviewed de novo)
Commonwealth v. Bass, 292 Va. 19 (2016) (ends-of-justice exception requires showing of grave injustice)
North Carolina v. Alford, 400 U.S. 25 (1970) (defendant may plead guilty while asserting innocence if evidence could convict)
Parson v. Carroll, 272 Va. 560 (2006) (explaining Alford plea in Virginia)