Commonwealth of Virginia v. Louis Scott Hudson

Summary

The Supreme Court of Virginia reversed the Court of Appeals' unpublished decision that had overturned Louis Scott Hudson's jury convictions for the second-degree murder of his wife and use of a firearm, and reinstated the trial court's judgment. The court held that the circumstantial-evidence instruction requiring the Commonwealth to exclude every reasonable theory of innocence does not add to the burden of proof beyond a reasonable doubt. It further held that the Court of Appeals misapplied the appellate standard by viewing the evidence in the light most favorable to Hudson rather than the Commonwealth, isolating favorable pieces of evidence, and failing to defer to the jury's credibility determinations and inferences; properly viewed, a reasonable jury could reject Hudson's suicide theory. No separate opinions were filed.