Edmonds v. Commonwealth
In Edmonds v. Commonwealth, 229 Va. 303, 329 S.E.2d 807, cert. denied, 474 U.S. 975, 88 L. Ed. 2d 324, 106 S. Ct. 339 (1985), a witness, Clark, saw appellant walking toward a small grocery store. See 229 Va. at 305, 329 S.E.2d at 809.
Ten minutes later, another witness, McDaniel, found the store owner dead inside the store. See id. That witness "saw Edmonds and another man standing at the front door." Id.
Edmonds left the scene when he heard the police sirens. See id. at 306, 329 S.E.2d at 810. Although a witness noticed "a stack of ones in the register" shortly before the murder, the police found no currency when they arrived. Id.
A twelve-year-old witness looked through the store window just before McDaniel discovered the body and "saw a man he later identified as Edmonds 'stooping below the cash register.'" Id.
Witnesses saw Edmonds with dollar bills after the murder. See id. Another witness testified that the victim "had told her that Edmonds had stolen some watches from his store and was no longer welcome as a customer." Id.
Another witness testified that Edmonds told her that the victim accused him of stealing the watches and "'said he was going to get the victim.'" Id.
After providing authorities with two earlier accounts incriminating someone else, Edmonds said he went to the store to buy a soft drink, at which time the victim aimed a pistol at him and asked about the stolen watches. See id.
Edmonds told the victim he paid for the watches, but the victim cursed him and threatened to shoot him, so Edmonds threw a brick at the victim, striking him on the head.
The victim dropped the gun momentarily, and, when he picked it up again, Edmonds grabbed a "butcher knife and 'the man got cut.'" Id. at 308, 329 S.E.2d at 811.
Edmonds claimed the victim was alive and calling for help when he left the store; on the way out, Edmonds said he "picked up a handkerchief and a bag of candy." Id.
Edmonds denied taking the gun or the money. See id.
In Edmonds, the Supreme Court did not use language requiring the Commonwealth to prove that the robbery was a motivating cause for the killing.
Instead, it found a sufficient causal connection between the murder and robbery to affirm the capital murder conviction by concluding "that the killing and the theft were interdependent objects of a common criminal design." Id. at 310, 329 S.E.2d at 813.