Ratliff v. Commonwealth

JAMES W. HALEY, JR., Judge.

Code § 18.2-51.4 states in relevant part: “Any person who, as a result of driving while intoxicated in violation of § 18.2-266 ... in a manner so gross, wanton and culpable as to show a reckless disregard for ... life, unintentionally causes ...” serious, permanent bodily injury shall be guilty of a Class 6 felony. (Emphasis added.) Paula Michelle Ratliff (“Ratliff’) entered a conditional guilty plea to a violation of this statute, preserving for appeal only her contention that, under the emphasized language, her intoxication must result from alcohol consumption,…