Larry Alonzo Oliver v. Commonwealth

D. ARTHUR KELSEY, Judge.

A jury found Larry Alonzo Oliver guilty of third-offense petit larceny. During the penalty phase of his bifurcated trial, the trial court admitted evidence of prior criminal convictions Oliver received from special military courts-martial under the Uniform Code of Military Justice. Oliver objected to this evidence, arguing that the criminal convictions were not convictions “under the laws of ... the United States” for purposes of Code § 19.2-295.1. The trial court rejected the argument, as do we.

Enacted by Congress and codified at 10 U.S.C. §§ 801-946, the provisions…