Horton v. Commonwealth

In these cases, we decide whether there is sufficient evidence of penetration to support the defendants’ convictions of forcible sodomy by engaging in cunnilingus in violation of Code § 18.2-67.1. Because the evidence in each case proves that the respective defendant penetrated the outer portion of his victim’s genitalia, we will affirm the convictions.

I. STANDARD OF REVIEW

The applicable standard of review is as follows:

Where the sufficiency of the evidence is challenged after conviction, it is our duty to consider it in the light most favorable to the Commonwealth and give it all reasonable…