Robert Lewis Clay v. Commonwealth of Virginia

Summary

The Court held that the trial court did not abuse its discretion by admitting the victim's statements expressing fear of Clay because those statements were relevant and probative of whether the killing was willful and deliberate. Assuming the exclusion of a deputy sheriff's testimony was erroneous, the Court held that the error was harmless under the newly adopted nonconstitutional harmless-error standard because the evidence overwhelmingly showed that the shooting was not accidental.