Michael Eugene Donati v. Commonwealth of Virginia

The majority apparently believes that as a policy matter a video recording is to be deemed more credible, as a matter of law, than the testimony of the most reliable and credible human witness. Consequently, it has found inapplicable the *580long standing rule in Schwartz v. Commonwealth, 68 Va. (27 Gratt.) 1025 (1876), requiring corroborating evidence to prove perjury. “If [Schwartz ] is to be overruled, ... it must be expressly overruled by the Supreme Court.” Bostic v. Commonwealth, 31 Va.App. 632, 636, 525 S.E.2d 67, 68 (2000). Because we are “constrained by our previous decisions and those…