Bellinger v. Commonwealth
In Bellinger v. Commonwealth, 23 Va. App. 471, 477 S.E.2d 779 (1996), the defendant was tried for voluntary manslaughter. See Bellinger, 23 Va. App. at 473, 477 S.E.2d at 779.
The Commonwealth introduced three disposition records for bad check offenses in the sentencing phase of the trial. See id.
On each of the warrant forms for the bad check offenses, "NO. JAIL 19.2-160," was stamped at the place designated for "'final disposition.'" Id. at 474, 477 S.E.2d at 780.
The record contained "no other notation of disposition and no formal order of conviction." Id.
The Court found that the documents submitted as orders of conviction for the bad check offenses "failed, in every respect, to satisfy" the requirement of Code 19.2-307. 23 Va. App. at 474-475, 477 S.E.2d at 780.