Patricia Ann Gerald v. Commonwealth of Virginia Tarsha Marie Gerald v. Commonwealth of Virginia

Summary

The Supreme Court of Virginia affirmed the perjury and driving-on-a-suspended-license convictions of Patricia and Tarsha Gerald, mother and daughter tried together in a bench trial in the Albemarle County Circuit Court. The court held the perjury evidence sufficient even though the general district court proceeding was unrecorded, because the investigating officer's contemporaneous notes captured the specific questions and the Geralds' sworn denials that they were driving on May 26, 2013. It held venue proper in Albemarle County because the Charlottesville city charter grants the county and city 'joint jurisdiction' over county property within the city, including the courthouse where the perjury was committed, making crimes there triable in either jurisdiction. Finally, it held that the eyewitness testimony placing Tarsha in the driver's seat after the accident was not inherently incredible, so the circuit court's credibility findings stood.