Whittaker v. Commonwealth
In Whittaker v. Commonwealth, 217 Va. 966, 968, 234 S.E.2d 79, 81 (1977), the Supreme Court addressed whether a criminal defense attorney had made a sufficient proffer when seeking to elicit answers from a prosecution witness about criminal sentences he had served.
Defense counsel stated to the judge what he thought the sentences were and that the witness had received lenient treatment from the prosecution in exchange for testimony. 217 Va. at 967, 234 S.E.2d at 80.
In applying the rules outlined above, the Court found that proffer sufficient. Id. at 969, 234 S.E.2d at 81.