Butcher v. Commonwealth
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The Supreme Court affirmed in part and vacated in part the judgment of the court of appeals affirming Defendant's conviction for misdemeanor failure to stop at the scene of an accident in violation of Va. Code 46.2-894, holding that the court of appeals correctly found that the evidence was sufficient to prove that Defendant had failed to satisfy either of two post-accident reporting requirements in the statute.
Upon affirming Defendant's conviction, the court of appeals further held that "to meet the statutory command, [Defendant] only needed to report forthwith the required information to one person described in the statutory list." The Supreme Court vacated this portion of the court of appeals' opinion, holding that the court of appeals did not have to agree with Defendant's concession of law that the statute's reporting requirements are disjunctive and that it was logically unnecessary for the court of appeals to address this undisputed legal issue.
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