Michael Lee Townsend, Sr. v. Commonwealth of Virginia, 270 Va. 325

Summary

The Supreme Court of Virginia affirmed the judgment of the Court of Appeals upholding Michael Lee Townsend's convictions for capital murder, first-degree murder, and firearm offenses. The court held that Townsend waived his argument that seating two prospective jurors would undermine public confidence in the judicial process because he did not raise that specific ground in the trial court. Applying Virginia Rule 5:25, the court declined to consider the public-confidence argument for the first time on appeal.

Holdings

1. A defendant's contention that seating a prospective juror would undermine public confidence in the integrity of the judicial process must be raised in the trial court with sufficient specificity; if not, the claim is waived under Rule 5:25 and cannot be raised for the first time on appeal.
2. The trial court did not commit manifest error or abuse its discretion in denying Townsend's motions to strike Holt and King for cause because the record supported the trial court's findings that neither juror demonstrated disqualifying bias and each could fairly perform the duties of a juror.

Questions Presented

1. Whether Townsend's argument that seating prospective jurors with close associations to a victim's family or a sheriff's deputy would undermine public confidence in the integrity of the judicial process was preserved for appellate review when it was not presented to the trial court.
2. Whether the trial court committed manifest error or abused its discretion by denying Townsend's motions to strike Holt and King for cause.

Disposition

affirmed