During the past year, the Court of Appeals of Virginia continued to be the major contributor to the development of substantive and procedural criminal law in the Commonwealth. Many of the court's decisions concerned the characterization of. police-citizen encounters in the context of both Fourth Amendment law and the rights of an accused under Miranda v. Arizona. A number of cases concerned the admissibility of uncharged misconduct, and the numerous double jeopardy opinions involved case-by-case application of Grady v. Corbin, Blockburger v. United States, and related statutes. A growing body of procedural law concerned the propriety of impanelling jurors of dubious impartiality. Many of the court's opinions illustrated deficiencies in the preservation of presenting issues for appellate review.
Steven D. Benjamin,
Annual Survey of Virginia Law: Criminal Law and Procedure,
U. Rich. L. Rev.
Available at: https://scholarship.richmond.edu/lawreview/vol27/iss4/8