Briley v. Commonwealth
In Briley v. Commonwealth, 222 Va. 180, 184-85, 279 S.E.2d 151, 154 (1981), Linwood Briley and his cohorts stopped their victim outside a restaurant, robbed him at gunpoint, forced him into his own automobile, abducted him, and took him to an island located in the James River.
Upon arrival at the island, approximately 15 to 20 minutes after the initial robbery, they shot him fatally.
They drove away in his car, which they later stripped of parts and abandoned.
The Court held that the murder was closely related in time, place, and causal connection to the robbery, making it a part of the same criminal enterprise as a matter of law. Id. at 544, 273 S.E.2d at 56.
Since Briley, the Court have affirmed convictions for capital murder during the commission of a robbery when the evidence was sufficient to support a conclusion that the killing and theft were interdependent objects of a common criminal design.