Commonwealth v. Carolino

PRESENT: All the Justices COMMONWEALTH OF VIRGINIA OPINION BY v. Record No. 230945 JUSTICE CLEO E. POWELL DECEMBER 12, 2024 PATRICK AUSTIN CAROLINO FROM THE COURT OF APPEALS OF VIRGINIA Following a bench trial, Patrick Austin Carolino was convicted of strangulation pursuant to Code § 18.2-51.6. After hearing the matter en banc, a majority of the Court of Appeals reversed the judgment, holding that the trial court erred in admitting collateral propensity evidence for the sole purpose of attacking Carolino’s credibility in violation of McGowan v. Commonwealth,

274 Va. 689

(2007) (“McGowan”).…