Cappe v. Commonwealth

Supreme Court of Virginia · February 13, 2025 · No. Record No. 240055

Summary

This Virginia Supreme Court per curiam opinion affirms Sh’Kise Fazion Cappe’s first-degree murder, firearm use, and conspiracy convictions. The court holds that the evidence presented at trial was legally sufficient to sustain the convictions under the applicable standard of review. Additionally, the court declines to address Cappe’s challenge to the Court of Appeals’ harmless error ruling because he failed to provide any supporting argument or authority in his brief, constituting a waiver.

Court
Supreme Court of Virginia
Jurisdiction
Virginia
Decision date
February 13, 2025
Docket number
Record No. 240055
Procedural posture
Appeal from a judgment of the Court of Appeals of Virginia.
Standard of review
Appellate deference – highest degree of review for sufficiency of the evidence; harmless‑error review requires a briefed assignment of error.
Precedential value
published
Parties
Cappe v. Commonwealth
Disposition
affirmed

Topics

criminal procedureappellate procedurestandard of reviewharmless errorevidence

Practice areas

criminal procedureappellate procedure

Questions Presented

  1. Whether the evidence was sufficient to support Cappe’s convictions for first‑degree murder, use of a firearm, and conspiracy.
  2. Whether the Court of Appeals erred in holding that the exclusion of Kirkendall’s identification testimony was harmless, given Cappe’s failure to brief the assignment of error.

Holdings

  1. The evidence was sufficient; the Court affirms the Court of Appeals’ judgment.
  2. Failure to brief an assignment of error constitutes a waiver; the Court declines to reach the merits of the harmless‑error claim.

Factual background

Cappe was linked to a shooting through video footage, cartridge casings, a vehicle registered to him, cell‑phone records, and text messages. The video showed three men firing at the victim; the faces were grainy, but the jury observed Cappe from multiple angles. A firearms expert linked a cartridge from Cappe’s car to the crime scene. The prosecution also presented text messages and cell‑phone tower data tying Cappe to the scene.

Procedural history

Cappe was convicted of first‑degree murder, use of a firearm to commit murder, and conspiracy. He appealed to the Court of Appeals, which affirmed the convictions and held that the trial court’s exclusion of a witness’s testimony was harmless. Cappe then appealed to this Court.

Court Document

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