Watkins v. Commonwealth

Ronald Watkins was convicted by a jury of robbery and of capital murder in the commission of robbery while armed with a deadly weapon, Code § 18.2-31 (d). At the conclusion of the first stage of the bifurcated trial, the jury fixed his punishment at life imprisonment on the robbery count. At the penalty stage of the trial, after hearing evidence of aggravating and mitigating circumstances, the jury returned a unanimous verdict fixing Watkins’ punishment at death for capital murder.

The jury based its verdict on both the “future dangerousness” and “vileness” predicates of Code § 19.2-264.4(C).…