State v. Scruggs (Signed Opinion)Annotate this Case
The Supreme Court in this case considered two certified questions regarding West Virginia's kidnapping statute, W. Va. Code 61-2-14a.
Defendant was indicted for kidnapping. During pretrial proceedings, the parties discussed (1) whether, under Alleyne v. United States, 570 U.S. 99 (2013), the judge or the jury would need to make additional determinations when considering a kidnapping charge and (2) the propriety of special interrogatories to the jury in a kidnapping case. Defendant's trial was continued so that these issues could be brought to the Supreme Court for consideration. The Court answered, for a person convicted of kidnapping, (1) the trial judge, rather than the jury, is vested with the authority under the kidnapping statute to determine those facts that reduce the minimum and maximum penalty of life imprisonment without eligibility for parole; and (2) in the absence of a statutory or constitutional requirement that special interrogatories be submitted to a jury in a kidnapping case, a trial court exceeds its authority and abuses its discretion in submitting special interrogatories to determine those facts that reduce the minimum and maximum penalty of life imprisonment without eligibility for parole.