Darien Vasquez v. Commonwealth of Virginia Brandon Valentin v. Commonwealth of Virginia

Summary

The Supreme Court of Virginia affirmed the convictions and aggregate sentences of two sixteen-year-old offenders sentenced to 133 and 68 active years, holding that Graham v. Florida's prohibition on life-without-parole sentences for juvenile nonhomicide offenders does not extend to multiple term-of-years sentences for multiple crimes, and that the evidence sufficiently proved the defendants possessed knives at the time they entered the victim's townhouse. The court reasoned that binding precedent consists of holdings rather than general language, that the average per-crime sentence was only 6.7 years, and that extending Graham would raise unanswerable line-drawing questions. It also clarified that the reasonable-hypothesis-of-innocence principle merely restates the Commonwealth's beyond-a-reasonable-doubt burden. Justice Mims, joined by Justice Goodwyn, concurred in the judgment but would have held that Graham applies to de facto life sentences, finding the outcome controlled instead by Virginia's geriatric release statute.