Case StudiesThreats & StalkingKeyes v. Commonwealth

Threats & Stalking Case Study

Keyes v. Commonwealth

📍 Virginia Court of Appeals📅 2011⚖️ Virginia Code § 18.2-60.3

Legal Issue

Whether the defendant's repeated contacts with the alleged victim constituted stalking under § 18.2-60.3.

Court Holding

The court affirmed the stalking conviction, finding that the defendant's repeated, unwanted contacts — including phone calls, text messages, and physical appearances at the alleged victim's home and workplace — constituted a course of conduct that would cause a reasonable person to suffer substantial emotional distress. The court held that the defendant's intent to cause distress could be inferred from the pattern of conduct.

Defense Takeaway

Stalking requires proof of a course of conduct — two or more acts — that would cause a reasonable person to suffer substantial emotional distress. D.J. Rivera challenges stalking charges by scrutinizing whether the alleged contacts were actually unwanted, whether the alleged victim communicated that the contacts were unwanted, and whether the contacts were sufficient to cause a reasonable person substantial emotional distress.

Relevant Virginia Law

This case involves § 18.2-60.3 of the Virginia Code. For a full analysis of how this statute applies to your case, consult with D.J. Rivera.

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