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The following case is Virginia case detailing what should be shown at trial to prove auto accident causation. The Jury awarded the Plaintiff $7,000,000.0o. If you have been injured in an auto accident you should call me at (434) 660-9701 for a free consultation.

Following trial in the Prince William County Circuit Court (the "trial court"), a jury found Sharon Furr ("appellant") liable for negligence in connection with a 2014 motor vehicle accident between appellant's car and another car in which the plaintiff, Tamara Al-Saray ("appellee") was a passenger. Appellant raises thirteen assignments of error on appeal, the first of which this Court finds dispositive of the entire case. As her primary argument, appellant asserts that the trial court erred in denying her motion to strike because appellee's evidence was insufficient to establish a prima facie case of negligence. Specifically, she argues that appellee did not present evidence establishing that appellant's breach of duty was a proximate cause of the car crash. For the reasons below, this Court agrees and finds that the insufficient evidence of causation warrants reversal of the trial court's judgment.


On November 10, 2014, at approximately 4:30 p.m., appellant's vehicle crashed into another vehicle driven by Janaia Spurlock ("Spurlock") at the intersection of Wellington Road and Market Place Avenue in Prince William County, Virginia. Wellington Road is a four-lane divided highway with two lanes of traffic in each direction-east and west-and the road slopes slightly uphill as one approaches the intersection with Market Place Avenue from the west. At the time of the accident, the traffic signal at the intersection was a solid green light for vehicles traveling east and west along Wellington Road.

Prior to the collision, appellant was traveling westbound in the right-hand thru lane on Wellington Road at approximately 45 miles per hour, the posted speed limit. Spurlock was traveling eastbound on Wellington Road and attempted to enter the shopping center on Market Place Avenue by making a left-hand turn across appellant's westbound lane of travel. The day was bright and the weather clear. As appellant approached the intersection she was looking straight ahead and had an unobstructed view of approximately 300 to 400 feet in front of her. Nevertheless, appellant claims she did not see anything in her path until she saw a "white blur" just before colliding with Spurlock's vehicle in the middle of the intersection.

When the two cars collided, the front of appellant's car struck the rear passenger-side door on the right-hand side of Spurlock's vehicle-where appellee was seated. Both Spurlock and appellee were 16 years old at the time of the accident. After impact, appellant's vehicle came to rest on the sidewalk just past the intersection, and Spurlock's car was facing east with its rear up against a light pole and its front in the intersection. Appellee sustained significant physical and neurological injuries as a result of the collision.

Nearly four years later, on March 29, 2018, appellee filed suit against both Spurlock and appellant, seeking compensatory damages for the injuries she sustained in the 2014 crash. Appellee alleged that both defendants were "jointly and severally" liable to her for their combined negligence. However, on October 8, 2021-only five days before trial commenced on October 13, 2021-the trial court granted appellee's motion to nonsuit Spurlock from the case and the trial court granted her motion to amend the case caption with appellant as the sole defendant.

Subsequently, appellee presented extensive evidence during trial to demonstrate that appellant needed to wear her reading glasses to see properly while driving and that she was not, by her own admission, wearing them on the day of accident. Appellee presented no evidence about Spurlock's actions leading up to the crash.

Pre-Trial Proceedings

During pre-trial discovery, appellant filed a motion for a Rule 4:10 neuropsychology exam of appellee to be conducted by Dr. Gary Kay. The trial court granted appellant's request on February 4, 2021, but included in the order a provision granting appellee's request to record the exam. Dr. Kay refused to comply with that provision and did not conduct the exam.

On March 2, 2021, appellant filed a motion for reconsideration in which she asked the trial court to order a second Rule 4:10 exam, this time by Dr. Jeffrey Wilken. The trial court granted appellant's request on March 29, 2021, and removed the mandatory recording provision from that second order. However, in an attempt to prevent any further issues, the trial court required appellant to confirm Dr. Wilken's review of the order and his willingness to abide by its terms. In particular, the trial court ordered appellee to "submit to an examination by Dr. Jeffrey A. Wilken," but made clear that no "substitute examiner" could conduct the exam unless appellant first received permission from the court or both parties mutually agreed to the alternate examiner. Dr. Wilken provided his written assent to those terms.

Both parties agreed that Dr. Wilken would conduct the exam on June 22, 2021. On that date, appellee arrived timely at the exam location with her attorney around 8:45 a.m. Dr. Wilken, however, was not present and instead sent an associate, Dr. Catherine Bergmann, who informed appellee that she would conduct the first part of the exam and Dr. Wilken would arrive at 11:30 a.m. to conduct the latter half of the examination. Based on this new information, appellee left the exam location after approximately thirty minutes and informed the trial court that Dr. Wilken had violated the court's order.

The parties cross-moved for sanctions, and the trial court granted sanctions in favor of appellee for Dr. Wilken's violation of the court's order that he be the one to conduct the examination. Pursuant to that determination, the trial court ruled that Dr. Wilken would not be allowed to testify as to why he had not conducted an examination. The court then ruled that it would not grant appellant's motion to exclude appellee's evidence of a traumatic brain injury and would not grant a continuance or issue a third order for a Rule 4:10 exam.

At a subsequent hearing, the trial court made several rulings regarding the admissibility of proffered testimony by appellant's expert witnesses. Regarding Dr. Falconer, the trial court prohibited testimony that appellee might have suffered from a "second-hit phenomenon" or that her brain injury could have been caused by a subsequent accident. Similarly, the trial court excluded testimony by Dr. Wilken that the delays in the presentation of appellee's symptoms might be consistent with a different cause, other than the 2014 wreck.

In making those admissibility determinations, the trial court relied on the expert disclosures appellant provided. Based on the language Dr. Falconer and Dr. Wilken used in their reports, the trial court concluded that their opinions were not made to a reasonable degree of medical probability and were thus too speculative for the jury to consider.

After the trial court entered the nonsuit order for Spurlock on October 8, 2021, it ruled that appellant could not offer any evidence that Spurlock had pled guilty to failing to yield in connection with the 2014 accident. Despite appellant's arguments to the contrary, the trial court ruled that any testimony about Spurlock's plea was inadmissible hearsay and there was no other basis for admission of such evidence. The court gave multiple reasons for this ruling, including that Spurlock was no longer a party opponent, the police officer who ticketed Spurlock in 2014 had no independent recollection of the accident or Spurlock's plea, Spurlock denied in her deposition to having been issued a ticket or pleading guilty, and all records of Spurlock's plea were sealed because she was a juvenile. Notwithstanding that ruling, appellant still announced her intention to subpoena Spurlock to testify at trial.

Trial Testimony and Proceedings

Trial commenced on October 13, 2021. Appellee introduced portions of appellant's deposition testimony at trial, as well as in-person testimony from several witnesses; but neither appellee, appellant, nor Spurlock testified in the trial court. In fact, the only other witness who was present at the scene of the accident-Greg Burke ("Burke")-did not see the moment appellant's and Spurlock's vehicles collided.

Burke testified that he had been driving westbound on Wellington Avenue in the right-hand thru lane at approximately 4:30 p.m. on November 10, 2014. When he reached the intersection at Market Place Avenue, he had a solid green traffic light and he moved into the right-hand turn lane so he could turn into the shopping center on his right. As he did so, he saw Spurlock's vehicle in the eastbound left-hand turn lane on Wellington Road. He described her as

having "slowed to a stop or was creeping at that point.... She was yielding to me." He did not see appellant's vehicle in the right thru lane behind him.

When Burke started making his right-hand turn, he saw that Spurlock's car "was at a hesitation or barely creeping at that point." Approximately four seconds after he started making that turn, Burke heard the crash of appellant's and Spurlock's vehicles colliding, but he did not see the moment of impact which had occurred behind him. He did not hear any horns honking or brakes screeching in those four seconds. During cross-examination by appellant's counsel, Burke confirmed that at the last time he saw Spurlock's vehicle prior to the crash "she had not yet entered the . . . left thru lane on westbound Wellington Road." He also affirmed that he "did not see whether Ms. Spurlock's vehicle or [appellant]'s vehicle entered the intersection first."

At the close of appellee's case-in-chief, appellant made a motion to strike the evidence on the grounds that it was insufficient to make out a prima facie case of negligence. The trial court denied that motion, along with appellant's motion to reconsider in which appellant drew attention to appellee's choice to call Burke-who saw neither the collision itself nor the manner in which Spurlock entered the intersection-rather than Spurlock herself. Appellant thus argued that, because Burke's testimony did not show that appellant "could have avoided the accident if she maintained a proper lookout," appellee had not presented evidence that would allow the jury to determine whether appellant's actions were a proximate cause of the accident.

Because appellee had "to show that [appellant] could have avoided the accident if she maintained a proper lookout," the complete absence of evidence about how Spurlock entered the intersection was critical to appellee's case. Appellant also made a renewed motion to strike, on the same grounds, at the close of all the evidence. The court denied that motion as well.

Prior to jury deliberations, appellant proposed two versions of Jury Instruction T, each of which included different portions of the statutory table of stopping distances in Code § 46.2-880. One version included the complete table in Code § 46.2-880, while the other version requested only the single horizontal row applicable to a speed of 45 miles per hour. The trial court declined to give either version and explained that existing case law required appellant to offer evidence establishing the reliability of each factor in the table as applied to appellant- including condition of the vehicle and roadway-before the contents of that table could be given to the jury. Appellant offered no such evidence.

During closing argument, appellee's counsel stated: "[Y]ou can't go 45 miles an hour into a sitting duck.... People get killed. A grandfather gets killed." A few moments later, speaking as if he were appellant, appellee's counsel said: "I drove into another car and I killed a man." Appellee never introduced any evidence that someone died as a result of the accident. A few moments after the second statement, but still during appellee's closing argument, appellant's counsel objected and moved for a mistrial. Appellant argued that appellee's statements were highly prejudicial and inappropriate, especially considering the complete lack of evidence that appellant had killed anyone. The trial court denied the motion for a mistrial on the sole basis that appellant had waived the objection by not making it contemporaneously with the offending statements.

The jury returned a verdict on October 21, 2021, finding appellant liable for negligence. It awarded appellee $7 million in damages.

Post-Trial Motions

At a post-trial hearing on December 3, 2021, appellant made a motion to set aside the verdict on the grounds that the evidence was insufficient as a matter of law to show that her negligence was a proximate cause of the accident. In particular, she asserted that the jury could not determine whether her conduct was a proximate cause of the accident without knowing when and how quickly or slowly Spurlock entered the intersection. The trial court denied appellant's motion, finding that it "comes down to one of sufficiency to the evidence; not one of a complete absence of evidence" and that the circumstantial evidence was sufficient for the jury to determine that appellant was a proximate cause of the accident.

Appellant also renewed her argument for a mistrial based on appellee's statements during closing arguments, but the trial court denied that motion again on the grounds that it had not been made at the time the words were spoken and thus appellant's objection was waived. The trial court then entered judgment "in the amount of $7 million with interest running as of the date of this order."

Appellant then filed a motion to reduce the amount of her appeal bond from the full amount of the judgment to her insurance liability limit of $500,000 dollars "in order to suspend the execution of the judgment in this case while it is on appeal." In support of that motion, appellant signed an affidavit stating that her only financial asset was the insurance policy. The trial court issued an amended final judgment on January 14, 2022, in which it denied appellant's request for lack of "good cause" shown and entered final judgment in favor of appellee for the full $7 million. This appeal followed.


Appellant raises thirteen assignments of error, grouped into several categories. First and foremost, appellant asserts the trial court erred in denying her motion to strike and subsequent motion to set aside the jury's verdict. She contends that appellee's failure to introduce any evidence of causation precluded appellee from establishing a prima facie case of negligence as a matter of law. As a result, she argues that the case should not have been presented to the jury and the jury's verdict in favor of appellee is contrary to the law because it is based on speculation.

This Court agrees with appellant's position and finds this initial issue dispositive. This case presents the relatively rare instance of there being multiple possible proximate causes of an accident but no evidence upon which a jury could base a finding on the issue of causation. Consequently, because "the doctrine of judicial restraint dictates that we decide cases 'on the best and narrowest grounds available,'" this Court declines to address the merits of appellant's remaining assignments of error. Butcher v. Commonwealth, 298 Va. 392, 396 (2020) (quoting Commonwealth v. White, 293 Va. 411, 419 (2017)).

Standard of Review

"As a general rule, [this Court] will not set aside a [trial] court's judgment sustaining a jury verdict unless it is 'plainly wrong or without evidence to support it.'" N. Va. Kitchen, Bath &Basement, Inc. v. Ellis, 299 Va. 615, 622 (2021) (quoting Parson v. Miller, 296 Va. 509, 524 (2018)); see also Elliott v. Anderson, 208 Va. 753, 760 (1968) (quoting Garrison v. Burns, 178 Va. 1, 8 (1941)).

Where the trial court has denied a motion "to strike the plaintiff's evidence or to set aside a jury verdict, the standard of appellate review in Virginia requires this Court to consider whether the evidence presented, taken in the light most favorable to the plaintiff, was sufficient to support the jury verdict in favor of the plaintiff." Ellis, 299 Va. at 622 (quoting Parson, 296 Va. at 523-24). In doing so, this Court considers the legal elements of the offense de novo, but reviews for clear error whether the facts presented are sufficient to prove those elements. Linnon v. Commonwealth, 287 Va. 92, 98 (2014). Accordingly, a trial court does not err in denying a motion to strike when the plaintiff meets its burden of showing a prima facie case. Vay v. Commonwealth, 67 Va.App. 236, 249 (2017).

Establishing a Prima Facie Case of Negligence

"All negligence causes of action are based on allegations that a person having a duty of care to another person violated that duty of care through actions that were the proximate cause of injury to the other person." Steward ex rel. Steward v. Holland Fam. Props., LLC, 284 Va. 282, 286 (2012). Thus, to establish a prima facie case of negligence, a plaintiff must offer sufficient evidence as to all four legally distinct elements: "a legal duty on the part of the defendant, [a] breach of that duty, and a showing that such breach was the proximate cause of injury, resulting in damage to the plaintiff." Blue Ridge Serv. Corp. of Va. v. Saxon Shoes, Inc., 271 Va. 206, 218 (2006). The third element, causation, is crucial to the outcome of this appeal.

"The proximate cause of an event is that act or omission which, in natural and continuous sequence, unbroken by an efficient intervening cause, produces the event, and without which that event would not have occurred." RGR, LLC v. Settle, 288 Va. 260, 292 (2014) (quoting Ford Motor Co. v. Boomer, 285 Va. 141, 150 (2013)); see also Wells v. Whitaker, 207 Va. 616, 622 (1966) ("To impose liability upon one person for damages incurred by another, it must be shown that the negligent conduct was a necessary physical antecedent of the damages."). Factual causation, "often described as the 'but for' or Sine qua non rule," is a necessary "element of proximate cause" and provides that a defendant is not liable for a plaintiff's injury unless such harm would not have occurred "but for [defendant's] negligent act." Wells, 207 Va. at 622. As a result, the term "proximate cause" represents a "descriptive phrase for the limits the law has placed upon an actor's responsibility for his conduct." Id.

In the context of vehicular accident cases, the Supreme Court has repeatedly held that "[n]egligence cannot be presumed from the mere happening of an accident. The burden is on the plaintiff . . . to produce evidence of preponderating weight . . . that the defendant was guilty of negligence which was a proximate cause of the accident." Elliott, 208 Va. at 757 (quoting Weddle v. Draper, 204 Va. 319, 322 (1963)); Wells, 207 Va. at 622 ("Negligence and an accident, however, do not make a case. As between them there must be a causal connection." (quoting Hawkins v. Beecham, 168 Va. 553, 561 (1937))). To satisfy that burden, the plaintiff must "show why and how the accident happened, and if that is left to conjecture, guess or random judgment, he cannot recover." Blue Ridge, 271 Va. at 218 (quoting Weddle, 204 Va. at 322); see also Bridgeforth v. Gibbs, 207 Va. 127, 134 (1966) (finding the jury's verdict "improperly based upon conjecture and speculation" where plaintiff did not carry burden "of showing where, how and why the accident occurred").

Thus, although the issue of proximate cause is generally a question of fact to be resolved by the jury, "[t]he evidence tending to show causal connection must be sufficient to take the question out of the realm of mere conjecture, or speculation, and into the realm of legitimate inference, before a question of fact for submission to the jury has been made out." Virginian Ry. Co. v. Haley, 156 Va. 350, 381-82 (1931). "Not every inference that springs to mind is legally sufficient." Norfolk &W. Ry. Co. v. Wright, 217 Va. 515, 520 (1976). In the absence of sufficient evidence of causation, a prima facie case of negligence does not exist as a matter of law, despite the existence of evidence establishing that the defendant breached a duty owed to plaintiff. See, e.g., Blue Ridge, 271 Va. at 218-19 (holding that the trial court "abused its discretion when it denied" defendant's motion to strike plaintiff's evidence and submitted the case to the jury in the "absence of a prima facie case of negligence").

An example of the strict operation of this rule is the Supreme Court's holding in Cooper v. Whiting Oil Co., Inc., 226 Va. 491, 496 (1984). Despite finding that defendant was "negligent" in its actions after plaintiff provided notice of a leak in a gasoline tank on her property, the Court found that "there was no evidence that such negligence was a proximate cause of the damages to the Landowners' properties." Id. The Court explained that, because "[t]here was no evidence as to the amount of gasoline that leaked into the ground before" plaintiff's notification, "the jury could not determine what damages resulted from gasoline leaking from the tank after [defendant] negligently refilled it." Id. (emphases added). The Court thus affirmed the trial court's decision to grant defendant's motion to strike plaintiff's evidence. Id. at 497.

In accordance with that legal principle, the Supreme Court has consistently held that plaintiffs relying on circumstantial evidence to make out a prima facie case, like in the case at hand, must ensure that such evidence is "sufficient to show that the causation alleged is 'a probability rather than a mere possibility.'" Bussey v. E.S.C. Rests., Inc., 270 Va. 531, 536 (2005) (quoting S. States Coop. v. Doggett, 223 Va. 650, 657 (1982)). As particularly relevant to this case, "circumstantial evidence must show more than that the accident resulted from one of two causes, for one of which the defendant is responsible and for the other of which he is not." Cooper, 226 Va. at 496; Sneed v. Sneed, 219 Va. 15, 18 (1978); see also Vaughn v. Huf, 186 Va. 144, 153 (1947) (finding that, in the absence of necessary facts, no prima facie case of negligence had been shown where "the accident may have been attributable to one of several causes, for some of which the driver of the car was responsible and for some of which he was not responsible"). Otherwise, where the evidence does not provide a basis for differentiating between equally probable causes other than "conjecture, guess, or random judgment," the jury's verdict will be impermissibly based on an arbitrary choice not grounded in the evidence and thus contrary to the law. Town of West Point v. Evans, 224 Va. 625, 628 (1983); see also Elliott, 208 Va. at 757 (holding that inferences "must be based on facts, not on presumptions" (quoting Weddle, 204 Va. at 322)).

In applying that rule to the facts here, as discussed below, this Court finds that appellee failed to make out a prima facie case because the circumstantial evidence she presented did not establish that appellant, even if in breach of a duty owed, was a proximate cause of the accident.

Appellee's Evidence Insufficient to Establish Proximate Cause

Even assuming that appellee's evidence was sufficient to establish the first two elements of duty and breach, the purely circumstantial evidence was nevertheless insufficient to show that appellant was a proximate cause of the accident. Therefore, as a matter of law, appellee did not present a prima facie case of negligence and the trial court erred in denying appellant's motion to strike.

This Court readily acknowledges that there is sometimes a thin line dividing the cases in which evidence of causation is sufficient to establish a prima facie case, thus warranting resolution by a jury, and those in which it is not. See RGR, 288 Va. at 293 ("In resolving the question of proximate causation, '[e]ach case necessarily must be decided upon its own facts and circumstances.'" (alteration in original) (quoting Banks v. City of Richmond, 232 Va. 130, 135 (1986))). Indeed, the Supreme Court has a long history of addressing the distinctions between those two lines of cases. According to that precedent, the case at hand falls squarely into the second category because appellee presented no evidence that would permit a jury to resolve the question of proximate cause without resorting to speculation. As previously stated, although a jury may properly weigh evidence and assess witness credibility, it may not engage in speculation or make inferences that do not arise from the facts presented. See, e.g., Burton v. Commonwealth, 58 Va.App. 274, 283 (2011) (holding that the trier of fact "determine[s] what inferences are to be drawn from proved facts, provided the inferences are reasonably related to those facts" (quoting Beck v. Commonwealth, 2 Va.App. 170, 176 (1986))).

This point is aptly illustrated by the Supreme Court's ruling in Sykes v. Langley Cabs, Inc., 211 Va. 202 (1970), that the question of proximate cause was properly left in the hands of the jury because the answer depended upon which witness's testimony the jury found more credible. There, each witness's testimony about the key facts at issue directly contradicted one another, resulting in conflicting theories of proximate cause. Id. However, each version of events, if believed to the exclusion of the others, provided a complete explanation as to the cause of decedent's death. Id. Therefore, as the Court recognized, the jury's determination of proximate cause was based upon the direct evidence of the witness whose testimony it credited. Id. at 209 (finding that the jury need not "base an inference upon an inference in order to deduce negligence from the circumstances" where the circumstantial evidence was "not uncertain or indefinite" and did "not rest upon presumption" (quoting Bly v. S. Ry. Co., 183 Va. 162, 175 (1944))).

In complete contrast to those circumstances is the jury's verdict finding appellant liable for the accident that injured appellee. Here, there was no conflict in witness testimony for the jury to resolve because no one from either vehicle testified at trial and there were no other eyewitnesses to the collision itself or physical evidence to explain why the crash happened. Rather, the evidence presented-viewed in the light most favorable to appellee-only establishes, at best, that the two vehicles collided in the intersection during Spurlock's attempt to make a left turn across appellant's lane of travel and that, prior to the crash, appellant had failed to keep a proper lookout because she wasn't wearing her glasses.

But to conclude that appellant was a proximate cause requires evidence that the accident would not have occurred but for her failure to keep a proper lookout. Stated another way, if the accident would still have happened even if appellant had worn her glasses and kept a proper lookout, then appellant cannot legally be a proximate cause. See, e.g., Rascher v. Friend, 279 Va. 370, 377 (2010) ("[Because] a jury reasonably could have found that [plaintiff] would have had no opportunity to avoid the accident even if he had maintained visual contact with [defendant]'s vehicle[,] . . . the alleged [contributory] negligence on his part would not have been a proximate cause of the accident as a matter of law."). Such a determination, however, cannot be made without knowing the location, movement, and speed of Spurlock's vehicle in the four seconds leading up to the crash. See McManama v. Wilhelm, 222 Va. 335, 340 (1981) ("By failing to show where, when and how [decedent] entered the intersection, the plaintiff has failed to show that any negligence of [defendant] was a proximate cause of the accident.").

The evidence shows only that Spurlock failed to yield the right-of-way to appellant when making her left-hand turn. But nothing shows the timing of Spurlock's actions in the four seconds after Burke made his turn. Did she immediately start slowly crossing the westbound lanes of Wellington Road, thus becoming a visible obstacle that appellant had ample opportunity to see and avoid? Or did Spurlock hesitate, even for just a second, before suddenly darting into appellant's path, thus depriving appellant of any opportunity to react in time to avoid the crash?

Under the second set of circumstances, appellant's negligence is entirely immaterial to the question of proximate cause because Spurlock's unexpected dash across appellant's lane of travel would have happened too quickly for appellant to avoid the collision by braking or swerving even if she had been wearing her glasses and had kept a proper lookout.

In the absence of such information, appellee's evidence merely creates three equally plausible theories of causation: (1) that appellant was the sole proximate cause of the accident, (2) that appellant's and Spurlock's actions were each proximate causes, thus rendering them joint tortfeasors, or (3) that appellant was not a proximate cause at all, notwithstanding her failure to keep a proper lookout. The third option exists if Spurlock was the sole proximate cause of the accident, as described above, whereby her intervening negligence would sever the causal connection between appellant's actions and the car crash. See Kellerman v. McDonough, 278 Va. 478, 493 (2009) (holding that, for a "subsequent proximate cause" to "relieve a defendant of liability for his negligence[,]" the intervening negligence between defendant's act and plaintiff's injury "must so entirely supersede the operation of the defendant's negligence that it alone, without any contributing negligence by the defendant in the slightest degree, causes the injury" (first quoting Williams v. Le, 276 Va. 161, 167 (2008); and then quoting Atkinson v. Scheer, 256 Va. 448, 454 (1998))).

The Supreme Court addressed an analogous situation in Elliott, 208 Va. 753, where it considered three different equally possible scenarios, based on a single set of limited facts, as to how and why the accident between a truck and pedestrian could have occurred. The Court ultimately concluded that "[t]here are no physical facts in evidence, or conflicts in defendant's testimony which alone, or taken with the physical facts, are sufficient to make out a prima facie case of negligence." Id. at 760. Like in Elliott, the jury here was left with a single set of facts that raised two conflicting conclusions of liability between which the jury had no way of distinguishing without resorting to conjecture and guesswork. Either appellant was liable for appellee's injuries because her negligence was the sole or joint cause of the crash (causation theories (1) and (2) above), or appellant was not liable because her negligence was not a proximate cause of the crash (causation theory (3) above).

As theorized above, if Spurlock had dashed in front of appellant's vehicle such that no reasonable person exercising due care and keeping a proper lookout could have avoided the collision, then Spurlock becomes a subsequent intervening cause and bars a finding of negligence against appellant. Thus, the unknown role that Spurlock played in the crash is the crucial missing link in appellee's evidence, without which the jury's determination of proximate cause could only have been based on impermissible speculation. See Weddle, 204 Va. at 324 ("Any conclusion drawn by a jury that the defendant was negligent in the operation of her automobile at the intersection based on the physical facts, which actually support neither theory of the accident by evidence of preponderating weight, would of necessity be based entirely on conjecture and guess as to why and how the collision occurred."). Accordingly, the trial court erred in allowing the case to reach the jury and in denying appellant's motion to set aside the verdict. See, e.g., Wright, 217 Va. at 520 (reversing verdict rendered in favor of plaintiff where "the evidence left the question of causal connection in the realm of conjecture, and the trial court left the jury free to speculate upon random [p]ossibilities rather than reasonable probabilities").

For the foregoing reasons, this Court reverses the verdict entered below and enters judgment in favor of appellant.


In resolving this case on the best and narrowest grounds, this Court finds the evidence presented at trial insufficient to establish a prima facie case of negligence against appellant. Because appellee did not introduce sufficient evidence of proximate cause, the trial court should have granted appellant's motion to strike rather than allowing the jury to render a verdict based on speculation and conjecture. Therefore, this Court reverses the trial court's judgment and orders the case be dismissed with judgment in favor of appellant.

Reversed and dismissed.

AtLee, J., dissenting.

I would find that there was sufficient evidence that appellant's negligence could have been a proximate cause of the accident, and the issue was properly submitted to the jury. Therefore, I respectfully dissent. I agree with the majority that the issue of whether appellant acted negligently is not at issue, and regardless, the evidence of her negligence was overwhelming. I do not agree, however, that there was insufficient evidence, as a matter of law, that her negligence proximately caused the accident and harm to appellee. More specifically, I disagree with the majority's conclusion that the absence of eyewitness testimony about the exact movement of Spurlock's vehicle in the four seconds before the crash meant there was insufficient evidence of proximate cause, requiring the jury to impermissibly speculate. In my view, there was sufficient evidence of appellant's negligence such that the issue of proximate cause was properly before the jury.

The majority holds that the absence of specific testimony as to how Spurlock's vehicle was moving in that sliver of time-the four seconds preceding the collision-means that a factfinder had no evidence upon which to find that appellant's negligence was the proximate cause of the crash. I agree that the moments leading up to the crash are essential, but do not believe we are left without any evidence as to what occurred in that window. I would therefore uphold the jury's verdict.

A. Standard of Review

"Ordinarily, proximate cause is a question for the jury. It becomes one of law only when the minds of reasonable men could not differ." Duncan v. Hixon, 223 Va. 373, 376 (1982). If reasonable men can differ, then "the verdict will not be disturbed." Id. Furthermore, where the trial court has denied a motion "to strike the plaintiff's evidence or to set aside a jury verdict, the standard of appellate review in Virginia requires this Court to consider whether the evidence presented, taken in the light most favorable to the plaintiff, [here, appellee], was sufficient to support the jury verdict in favor of the plaintiff." N. Va. Kitchen, Bath &Basement, Inc. v. Ellis, 299 Va. 615, 622 (2021) (quoting Parson v. Miller, 296 Va. 509, 523-24 (2018)).

B. Evidence of Causation

In my view, the issue of proximate cause was properly presented to the jury. "When a verdict is based on circumstantial evidence, '[a]ll that is required is that a jury be satisfied with proof which leads to a conclusion with probable certainty where absolute logical certainty is impossible.'" Chase v. Breit, 226 Va. 102, 104 (1983) (alteration in original) (quoting Bly v. S. Ry. Co., 183 Va. 162, 176 (1944)). "If the facts proved support a reasonable inference that the act occurred, a jury issue exists." Id. Although proof of causation cannot be based on mere conjecture or speculation, the evidence here was sufficient to allow the jury to reasonably conclude that appellant was a proximate cause of the collision and resulting harm to appellee.

As the majority thoroughly sets forth the pertinent case law on negligence and proximate cause, I will not repeat it here. Crucially, however, we are mindful that "[a] green light is [not] an unqualified command to a motorist to move in the direction indicated under any and all circumstances. It is only a command to do so in the exercise of reasonable care ...." Medlar v. Mohan, 242 Va. 162, 167 (1991) (second and third alterations in original) (quoting Damron v. Hagy, 220 Va. 455, 457 (1979)). Thus, "[t]he duty of maintaining a proper lookout requires the favored driver to be on the alert for a motorist who attempts to drive through the intersection." Hodnett v. Friend, 232 Va. 447, 451 (1987). This "duty to keep a proper lookout . . . requires ordinary care to look in all directions for vehicles that would affect their driving, to see what a reasonable person would have seen, and to react as a reasonable person would have acted to avoid a collision under the circumstances." Henderson v. Gay, 245 Va. 478, 481 (1993) (emphasis added).

In this case, the accident occurred in the afternoon on a clear, sunny day in dry conditions. The intersection was large, with four wide traffic lanes going each direction-eight total, with a grassy median in between.[23] Appellant testified that she had 300 to 400 feet of "unobstructed view" of the roadway. There was a slight incline, but, as appellant testified, and the photographic exhibits and Burke's testimony confirm, it did not obstruct her view of the intersection. Appellant was driving in the right-hand through lane at the time of the collision.

Burke, who was driving in front of appellant in the right-hand through lane before getting into the right turn lane, noticed Spurlock's vehicle at the intersection. Spurlock was facing the opposite direction, waiting in the left-hand turn lane. At that time, Burke said Spurlock was "slowed to a stop or was creeping at that point....She was yielding to me." Burke said that Spurlock's vehicle was "completely visible" and was "obvious[ly]" waiting to turn left. Burke started to turn right, and approximately four seconds later, heard the crash.

Appellant, driving behind Burke, noticed none of this. Crucially, the point of impact was the rear passenger's-side of Spurlock's car. In order for Spurlock to be in that position, she had to cross multiple open, visible lanes of traffic-three to be in front of appellant in her lane, and almost four to be in the position she was in at the time of impact. Most of Spurlock's vehicle had to have already crossed directly in front of appellant's vehicle in order for her to strike the rear portion of the vehicle. Appellant did not brake, swerve, or otherwise try to avoid the collision. And how could she, given that by her own testimony, she never saw Spurlock's vehicle before impact, only a "white blur."

Under these circumstances, I do not believe we are without any evidence of causation. The majority finds there are three "equally plausible" theories of causation, the third of which being that appellant's negligence "was not a proximate cause at all, notwithstanding her failure to keep a proper lookout." This third option comes into play "if Spurlock had dashed in front of appellant's vehicle such that no reasonable person exercising due care and keeping a proper lookout could have avoided the collision." But, even accepting the premise that Spurlock darted in front of appellant, a reasonable person exercising due care would have, or should have, noticed a vehicle approaching them from the left, across a wide intersection with multiple lanes of traffic. It is reasonable to infer from the evidence (particularly when viewed in the light most favorable to appellee, the prevailing party) that appellant, in the exercise of due care and while maintaining a proper lookout, would have observed Spurlock's vehicle prior to impact-as did Burke-and respond with some defensive or evasive action. But she did not. There is no evidence, viewed under the correct standard, that suggests that appellant, as a matter of law, could not have acted to either avoid or to mitigate the severity of this accident. Instead, given the point of impact on Spurlock's car, a reasonable factfinder could conclude that had appellant slowed down even slightly, Spurlock's entire vehicle might have made it past her, and the accident might have been avoided, or the impact would have been greatly lessened. Accordingly, I do not believe the evidence is such that "the minds of reasonable men could not differ," Duncan, 223 Va. at 376, and I would not disturb the jury's verdict. See Va. Const. art. I, § 11 ("[I]in suits between man and man, trial by jury is preferable to any other, and ought to be held sacred.").

Further, I believe that adopting the majority's view places appellant in a better legal position for never having seen Spurlock's vehicle than she would have been had she seen it prior to impact. In that view, appellant's failure to see Spurlock, given there being no direct eyewitness testimony about the vehicle's movements in the four seconds immediately prior to the accident, renders the issue of proximate cause speculative. But, had appellant seen Spurlock, her observations and her reactions thereto would have been tested and, even under the majority's reasoning, would have created a jury issue and thus not warrant reversal. I find it troubling that appellant should benefit from her own inattentiveness and poor eyesight which, as the jury found in rendering its verdict, was a circumstance attributable to her own negligence.

Of course, like all such cases, this is fact-dependent. The accident occurring in a large intersection with many lanes and clear visibility is entirely distinct from, say, a winding road with hidden drives from which Spurlock's sudden movement would have more understandably caught appellant unaware. But those are not the facts before us. Had appellant been wearing her glasses, or otherwise been attentive to her surroundings, she would have noticed other vehicles on the roadway, most crucially Spurlock's, and could have taken some precautions that would have made it possible to avoid the accident. Had she been paying attention so that she saw Spurlock approaching before the vehicle was in front of her, or even reacted in any way as Spurlock passed in front of her, she could have at least attempted to slow down or otherwise avoid the collision. The utter lack of evidence that appellant either noticed or reacted to Spurlock until Spurlock had nearly driven past her, combined with her documented negligence and the affirmative evidence that Spurlock was otherwise visible, in my view, presents adequate evidence that appellant's negligence was a proximate cause of the accident. In other words, the evidence of causation was "sufficient to take the question out of the realm of mere conjecture, or speculation, and into the realm of legitimate inference." Virginian Ry. Co. v. Haley, 156 Va. 350, 381-82 (1931). Given the affirmative evidence of appellant's negligence, together with the reasonable inferences to be drawn therefrom, the issue of whether appellant's negligence was a proximate cause of the accident (and, hence, the injuries suffered by appellee) was properly before the jury, and I am loath for this Court to substitute its judgment for that of the jury. For these reasons, I respectfully dissent.
Furr v. Al-Saray (Va. App. 2023)


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Automatic Disclosure of “Mugshots,” A Blatant Due Process Violation




We have come to live in a society based on insults, on lies and on things that just aren’t true. It creates an environment where deranged people feel empowered.”[1] Corruption, injustice and utter disregard for some of the most basic human rights is continually infringed upon by federal, state and local law enforcement. Law enforcement fosters disrespect for themselves through this practice. I just pray that this stops before there is another Brian Banks.[2]  Or, on the other hand, the system produces another O.J. Simpson result.[3]

“Publishing mugshots before suspects have been tried undermines a sacred tenet of American jurisprudence.”[4] The automatic disclosure of mugshots is a U.S. Constitutional Due Process Clause violation and therefore unconstitutional. Booking photos are more commonly known as “mugshots.” They are the photograph taken during the intake process of arrestees by law enforcement. Upon arrest, most state governments immediately release mugshots on the internet. The U.S. federal government no longer releases mugshots of arrestees unless, there are extenuating circumstances (i.e. fugitive from justice) because they are “the vulnerable and embarrassing moments immediately after [an individual is] accused, taken into custody, and deprived of most liberties and fit squarely within this realm of embarrassing and humiliating information.”[5]

  1. The Background of “Mugshots”
    1. Legitimate purposes:

Whenever the government seeks to impose its power or interfere in the lives of citizens, it

must do so within the bounds of the U.S. Constitution, and that requires laws be “rationally related to legitimate government interests.”[6] Objectively, it is a legitimate government interest for the authorities to take a mugshot during the intake process of an arrestee. The sole purpose of which must be for release if an accused absconds or is generally a fugitive from justice. There is no other legitimate state purpose in the pre-hearing release of mugshots, none. To the contrary, in a charge anyone for anything without even basic probable cause atmosphere, the prehearing release of mugshots only serves an abhorrent agenda or equally as worse the local incompetent law enforcement officer.

If there is a conviction and the nature of the charge warrants notice to the public, then it would be a legitimate state interest to release a mugshot after the conviction, but not before![7] However, this still does not objectively sanction the pre-hearing release of mugshots. Notice to the public must also serve a legitimate state purpose in that the notice should be for the purpose of preventing recidivism.

  1. Illegitimate purposes:

The illegitimate purposes related to the pre-hearing release of mugshots is insurmountable

and undeniable. Today, there are people working within our government that would utilize their  entrusted power to harass their political opponents for no other reason than opinions. Not the law, and do so in the most unethical, unprofessional and generally underhanded ways.[8] What is immensely important with that assertion is that there really is no legitimate state purpose in the pre-hearing release of mugshots because the motives of authorities in our nation is not always legitimate, and has amounted to nothing short of an abuse of power on numerous occasions.[9]

Police arrested 3,621,299 people in 2020 according to the Federal Bureau of Investigation.[10] Unfortunately, the FBI does not track through the Uniform Crime Report the number of citizens that have been arrested, but not convicted. Because, that would be a true demonstrator of the economic impact of these unconstitutional pre-hearing disclosures. This seems convenient as a self-serving law enforcement funding inducer, of turning a blind eye to the inaccuracies of law enforcement conduct. The more credibility that is provided to law enforcement, the more non-allocated funding law enforcement will agencies receive. Where funding allocation towards accuracy in their official conduct should prevail, instead they spend on militarizing and firearm wielding robots.[11]

  1. Damages:

The definition of “what damages are?” related to mugshots can be straightforward and at the same time, elusive.[12] The real question of damages must be a question placed to a jury.[13] The Supreme Court of the United States has examined damages in multiple defamation suits and, as part of that analysis utilizes all of the facts and circumstances surrounding a case. For example, the application of a “malice standard.”[14] If an official state actor, like a law enforcement officer, is acting without diligence or worse under unapplicable political motivation or gross incompetence there is malice.

In any event, the pre-hearing release of mugshots really amounts to an extreme defamation by state governments. The monetary economic damages of which are astronomical. Most employers do a background check of some sort on new employees. Or, at least a quick internet search. If a mugshot of a potential employee pops up regardless of innocence, they are less likely to get hired. That fact is undeniable. For that sole purpose, there serves little legitimate argument that there is no “government taking” when there is a pre-hearing release of a mugshot. A “government taking,” is what triggers the right to Constitutional Due Process.[15]

Affecting someone’s employment prospects is certainly a matter the Supreme Court of the United States has recognized as a Constitutional Right.[16] Because, it is not the governments place to take from citizens without a hearing. Government taking without an opportunity to be heard, is a general usurpation of the Declaration of Independence, the Due Process Clause of the Fourteenth Amendment and the Universal Declaration of Human Rights.

  1. Freedom of Information Act (FOIA)

Legislatures rest their analysis on the reasoning of government transparency as to why a prehearing release of mugshots is warranted. However, this is a false analysis, because mugshots are minimally related to the government conduct at the center of FOIA’s reasoning. FOIA was enacted to shed light on government conduct not to harass the natural born United States Citizen.

  1. Background of FOIA:

The Freedom of Information Act was enacted so that concerned citizens could monitor government conduct. Previous to FOIA government agencies had a tendency not to disclose requested information to the public.[17] The Freedom of Information Act was meant to change that. Upon the enactment of FOIA, state legislatures followed suit and some had already enacted their own form of FOIA. Unfortunately, that has resulted in a disjointed conflagration of interpretations by Federal Courts regarding FOIA and a whole separate analysis for State Courts.

FOIA has an exemption to disclosure that mentions privacy. This exemption directly, references that which would “…constitute an unwarranted invasion of personal privacy.”[18] Since the establishment of this exemption to FOIA disclosure, only one of the four Supreme Court of the United States cases have favored disclosure over non-disclosure.[19] The Court in the unfavorable non-disclosure case of Department of the Air Force v. Rose, the Court relied on the legislative history for statutory interpretation.[20]

  1. Privacy Analysis and FOIA:

The Court in World Publ’g Co. v. United States DOJ asserted that there is a test in order to determine if there is an unwarranted invasion of personal privacy in favor of non-disclosure.  “A court must (1) determine if the information was gathered for a law enforcement purpose; (2) determine whether there is a personal privacy interest at stake; and if there is (3) balance the privacy interest against the public interest in disclosure.”[21]

The first prong of this test is satisfied, for there is little dispute that mugshots are taken for a legitimate law enforcement purpose. For example, if an accused attempts to abscond, generally become a fugitive from justice or escape from custody. For those reasons a mugshot should be taken to later release to the public if the authorities need to look for someone. Therefore, it is reasonable that law enforcement take mugshots.

For the second prong of the test, the Court found that "the fact that an event is not wholly private does not mean that an individual has no interest in limiting disclosure or dissemination of the information."  A “booking photo is intended for use only by a specific and small group of people—further reason for a court to protect an individual's privacy interest in that photo.”[22] Just because there is a legitimate government interest rationally related to mugshots, does not mean the government should be disclosing these mugshots publicly to just anyone for any reason automatically.

An analogy to this assertion is that in all jurisdictions a civil litigant or person of subject in litigation has a right that their social security number not be disclosed publicly, why should a mugshot be any different absent purpose and circumstance?[23] If you have a right to privacy in your social security number, a number on a piece of paper, then in what realm does logicality proffer that you have no right to privacy in a photo taken in one of the most vulnerable moments? Through very basic reason, we see that there is a foundational privacy interest.

The third and final prong of the test dictated is the balance of the first two. The Court opines that release of a mugshot:

“is not fostered by disclosure of information about private citizens that is accumulated in various governmental files but that reveals little or nothing about an agency's own conduct. In this case—and presumably in the typical case in which one private citizen is seeking information about another—the requester does not intend to discover anything about the conduct of the agency that has possession of the requested records.”[24]

In most of the cases surrounding this matter, it is the media that is the proponent of automatic disclosure. Congress did not intend for those that run the national media’s schadenfreude departments to be served by FOIA, to sully the good names of people whom may themselves be the victim of some setup, predatory act, lack of law enforcement diligence or general lie.[25] Not everyone who has had their mugshot taken has been the subject of proper cause, objective law enforcement action or general fairness and reason. Some have been the subject of a predatory act of the accuser.[26]

In sum, we see by careful examination of the case law surrounding privacy and the Freedom of Information Act, that controlling Courts recognize a legitimate privacy interest in mugshots and in favor of non-disclosure. Courts have had this issue presented to them numerous times throughout the history of FOIA and more often than not they find in favor of the individual’s privacy interest. The issue is no longer at the federal level but at the state level.

Due process is a basic requirement under the Fourteenth Amendment of the U.S. Constitution.[27] It is well founded that your name, image and likeness (a photo of you) is your property and especially if a person or entity attempts to use it for commercial purposes or if the government seeks to deprive you of your property.[28] This is true both domestically, internationally and biblically.[29] However, for the purposes of this section we will focus on the U.S. Constitution and the rights the Founders and Veterans risked everything for.

  1. Background of Due Process:

The Due Process Clause of the United States Constitution provides foundational protection against arbitrary decisions by legislatures, law enforcement and institutional injustice.[30] Due process is a basic requirement under the U.S. Constitution that “a person may not constitutionally be deprived of “life, liberty or property” by governmental action without notice and a meaningful opportunity to be heard.”[31] The following case is controlling law to determine if the Due Process Clause of the U.S. Constitution applies to a government taking.

In Mathews v. Eldridge, the court prescribes a test as to whether a matter is a Due Process violation.[32] The factors that are described by the court for due process are essential to our understanding of what due process protects. Due Process protects against erroneous deprivations by the government. The Court described the following test:

“…due process generally requires consideration of three distinct factors: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.”[33]

  1. Analysis of Due Process to Mugshots:

When applying the Mathews test we look at each factor. With the first factor, it becomes clear that the private interest affected by law enforcement charging and arresting an individual; and then releasing a mugshot without a hearing is an erroneous and capricious deprivation. The systemic inherent effect on the future trajectory of a person who has had their mugshot released is obvious, and certainly so in the internet age. In other words, there is a clear taking by the government when they post these photos on the internet. For anytime something is posted on the internet, it is there in perpetuity. It is there for any future employer, associate, third party or those that would seek to defame but for the sole purpose of their own salaciousness. The first prong of the Due Process Clause test is violated, unequivocally.

Next, we turn to the Courts second factor in Mathews, which is far simpler to address. This factor, when evaluating mugshot releases, is clearly violated and requires little discussion because there is no hearing or procedure whatsoever. Currently, there is no hearing before the government releases a mugshot to the public. Unless a citizen is arrested by the Federal Government, their mugshot is released.[34] The legislature is supposed to be bound by the United States Constitution and has utterly denied and ignored this. They have achieved this by disregarding the right to cross-examine evidence in an open public court.[35]

Finally, we address the Courts last prong of the Mathews test as to whether a matter violates Due Process. The Government has no legitimate interest in the pretrial, pre-hearing release of mugshots. To the contrary, this has economic implications on those that are falsely accused and matters that are generally unfounded. Unless a person is convicted or a fugitive from justice there serves no legitimate state interest in the release of mugshots. And, let’s say hypothetically for some unclear reason that the government interest were served by releasing these mugshots. The burden of including a hearing on the matter is de minimis and could easily be addressed at the first hearing related to matters. Our judicial system in general is a slow engine, there serves no legitimate purpose in the selective outrage of expeditiously releasing mugshots as opposed to waiting for a proper hearing. In any event, the burden would not be great for courts but that’s only if you get to that prong of the test, which we do not because of the former.

  1. Analysis Competing Opinions:

The United States Supreme Court has addressed the issue of mugshot disclosure and Due Process in Paul v. Davis in 1976. In a Split decision the Court asserted that a person does not have a Due Process interest in that “The words "liberty" and "property" as used in the Fourteenth Amendment do not in terms single out reputation as a candidate for special protection over and above other interests that may be protected by state law.” [36] But, we must bear in mind that Justice Rehnquist wrote this opinion well over forty seven years ago in 1976, decades before the public use of the internet and therefore the employment effects of these acts not fully recognized as herein today. To the contrary, in 1976 TV’s were large cub boxes, most got their news from a piece of paper and phones were tied to wires.

The employment discussion is important, because today you will be looked over for employment based solely on things like internet besmirchments.[37] And, in Justice Rehnquist’s opinion he specifically cited employment as a reasonable Due Process applicable right in that the “drastic effect of the "stigma" which may result from defamation by the government in a variety of contexts, this line of cases does not establish the proposition that reputation alone, apart from some more tangible interests such as employment.” Today the internet is used to harass on a level not cognizable in 1976, nefarious groups can incessantly molest others through its maleficent use, and the authorities do little to curb this.[38] In 1976, it just was not the case as today.

Within Paul v. Davis, the Court specifically references cases in relation to privacy law like Roe v. Wade and other cases that the authority has since changed. The Court opines about privacy law and this is also a vital consideration because the evolution of privacy law since 1976 has been substantial.[39] The Supreme Court of the United States, over the decades has increasingly recognized privacy interest since it issued the Davis opinion.

Furthermore, three Justice’s Brennan, Marshall and White dissented in Paul v. Davis. The distinguished dissenting justices with Brennan writing, opined that “The Court accomplishes this result(depriving citizens of a right to a hearing) by excluding a person's interest in his good name and reputation from all constitutional protection, regardless of the character of or necessity for the government's actions. The result, which is demonstrably inconsistent with our prior case law and unduly restrictive in its construction of our precious Bill of Rights, is one in which I cannot concur..”[40] As with a lot of matters in the law, from time to time it becomes necessary to reexamine issues that have been presented in the past.[41] Otherwise old and generally antiquated opinions would remain in effect indefinitely.

  1. The Supremacy Clause

The U.S. Constitution, because it is the supreme law of the land has in its inherent ability and applicably the authority to invalidate state law. Because, “the court is “bound” by the statute; the legislature is “bound” by the constitution.”[42] The Court can invalidate state statutes when they are found to violate the United States Constitution.[43] This is known as judicial review. Judicial review is a tool used by courts and is a part of the basic notion of checks and balances in the government.[44] Because, when we think about our rights as U.S. citizens, we should not be thinking about one branch of government over the other. The Founders intended for each branch of government, the legislature, the executive, and the judiciary to protect our rights as U.S. Citizens.

Nothing is safe while legislature is in session and the U.S. Supreme Court understood this over two hundred years ago when it issued its opinion in Marbury v. Madison. In Marbury, the Court first established that it had the power to overturn an act of legislation when it violated the U.S. Constitution.[45]

  1. Federal Law Enforcement Standard:

After significant opposition from the media, Federal law enforcement no longer

automatically release mugshots of arrestees. Today, if you are arrested by federal law enforcement your mugshot will not be released automatically.[46] This is also true in two states, but not most.[47]

  1. Th Internet Mugshot Industry
    1. Background Criminal Liability:

Companies like Arrests.org post photos of arrested citizens on the internet and then utilize ad revenue generated by these postings “click bate” to make money. Also, they charge persons money that would like the mugshots removed.[48] This is a form of extortion, but law enforcement has failed to prosecute this except for a few circumstances.[49]

  1. Background Civil Liability:

Often, in order to instill real change civil liability must be pursued by interested parties. Because, if you do not sue tortfeasors and falsehood perpetuators, everyone else will believe that what they are doing is what is correct. Or, generally not hurting anyone and the conduct will continue. Wrongdoers must not be permitted to profit from their own wrongdoing.

  1. Analysis Defamation:

Defamation is a false statement written or spoken about another person.[50] There have been successful defamation suits against the mugshot industries publishing’s.[51] Defamation can either be libel or slander. The dissemination of Mugshots is libelous. And, certainly if an accused has been done so falsely, for as the Supreme Court has opined “Imputing criminal behavior to an individual is generally considered defamatory per se.”[52] If an individual is later exonerated for the reasons a mugshot was taken then the civil defamation liability is clear and absolute.

  1. Analysis ‘Name, Image, Likeness’/Misappropriation:

In the United States, most States and the Federal Government have laws against using another person’s photo without their permission in a trade or business. Often this is referred to as Misappropriation. In Virginia, this is § 8.01-40 or the unauthorized use of name or picture of any person, this statute also serves as criminal culpability.[53] Punitive damages are awardable under this section. The law is fairly straight forward in this area. If you do not have permission to use another person’s photo, your breaking the law and at a minimum committing a tort. At a maximum you are committing a misdemeanor. Criminal acts are prima facie torts and damages are most certainly recoverable against the culpable.

  1. Analysis Intentional Infliction of Emotional Distress:

The online mugshot industry is tortiously and continuously committing intentional infliction of emotional distress. The elements for Intentional Infliction of Emotional Distress are “(1) the wrongdoer's conduct is intentional or reckless; (2) the conduct is outrageous and intolerable; (3) the wrongful conduct and the emotional distress are causally connected; and (4) the resulting distress is severe.”[54]

Applying these elements to the internet mugshot industry is no stretch. They corner their conduct on the notion that if an accused feels enough pain they will pay to have their mugshot removed from the website. That is their business model. This is nothing short of criminal extortion and prima facie Intentional Infliction of Emotional Distress.

  1. Analysis Pursuing judgements in foreign based entities:

The internet mugshot industry has been sued more times than we can reference in this paper. For that reason, they have sought to conceal their ill-gotten gains through foreign registered entities. Currently, Arrests.org an internet mugshot company, befuddles their plunder in Saint Kitts & Nevis. Saint Kitts & Nevis is one of these shelter islands in the Caribbean. People seeking to hide their money register companies there, because if they did not, they would be sued into bankruptcy. If you want to know if a company is legitimate, look at where they keep their money. The Federal Communications Commission and the Federal Bureau of Investigation should do more to stem the impact of foreign based entities smearing citizens on American soil. This is equivalent to breaking the law and getting paid to do it.

  1. International Law[55]


“Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression, the right to work and education, and many more.  Everyone is entitled to these rights, without discrimination.”[56] We must not only apply human rights internationally, they mean as much locally, with our neighbors, the people across town and throughout the nation.

In this section we will examine the applicability of international law to the automatic disclosure of mugshots. Specifically, the Universal Declaration of Human rights, right to dignity, due process and equal protection of laws. The Christian worldview is also applicable to the international law analysis, “love your neighbor as yourself.”[57]

  1. Universal Declaration of Human Rights


“We the Peoples of the United Nations Determined to save succeeding generations from the scourge of war, which twice in our lifetime has brought untold sorrow to mankind, and to reaffirm faith in fundamental human rights, in the dignity and worth of the human person, in the equal rights of men and women and of nations large and small, and to establish conditions under which justice and respect for the obligations arising from treaties and other sources of international law can be maintained, and to promote social progress and better standards of life in larger freedom.”[58] The preamble of the UDHR must apply to all generations, the ones that drafted the UDHR and in perpetuity.

  1. Analysis Article 1: Dignity


According to Article One of the Universal Declaration of Human Rights, “All human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act towards one another in a spirit of brotherhood.”

Article One is unequivocally violated when we examine the unreasonable and illegitimate state purpose of automatic booking photo disclosures. “If there are no constitutional restraints on such oppressive behavior, the safeguards constitutionally accorded an accused in a criminal trial are rendered a sham, and no individual can feel secure that he will not be arbitrarily singled out for similar ex parte punishment by those primarily charged with fair enforcement of the law.”[59]

  1. Analysis Article 7: Equal protection of Laws


According to Article Seven of the Universal Declaration of Human Rights, “All are equal before the law and are entitled without any discrimination to equal protection of the law. All are entitled to equal protection against any discrimination in violation of this Declaration and against any incitement to such discrimination.”

Equality in the law means that the law must be applied similarly to all parties. A person with ill intent should not be allowed to make a claim to the authorities that logically on its face makes no sense, and then hide their own identity whilst the person they accuse has their name dragged through the mud publicly with automatic booking photo disclosures. The truth of the matter is, that our law enforcement does not always act with fair enforcement of the law and sometimes acts under their own personal biases with no protection provided to the public. For this very reason, the power to destroy a persons career through automatic booking photo disclosures must stop immediately. This also has racial discrimination implications.

“As the drafting history (of Article 7) indicates, this clause was adopted with the understanding that it protected against propaganda of national, racial and religious hostility and hatred, as well as the understanding that although Article 19 protected freedom of expression, it did not protect expression that incites discrimination.”[60] Race based discrimination is enacted with automatic mugshot releases, it creates a stereotype perpetuated for minorities.[61]

Authorities put mugshots into computers using algorithms and face recognition technology.[62] These actions perpetuate a racist system by recycling old mugshots essentially recycling the past. Thus, because minorities are more likely to be detained and have their booking photo taken, this is a racist practice because the system is racist.

  1. Analysis Article 10: Due Process

According to Article Ten of the Universal Declaration of Human Rights, “Everyone is entitled in full equality to a fair and public hearing by an independent and impartial tribunal, in the determination of his rights and obligations and of any criminal charge against him.”[63]

This is highly similar if not the exact same right provided by the United States Constitution. The authorities are not to take from citizens unless they have been provided a fair hearing. “Police officials, acting in their official capacities as law enforcers, may on their own initiative and without trial constitutionally condemn innocent individuals as criminals and thereby brand them with one of the most stigmatizing and debilitating labels in our society.”[64] And, this is done in perpetuity thanks to the illegal online mugshot industry.

“The right to be heard before being condemned to suffer grievous loss of any kind, even though it may not involve the stigma and hardships of a criminal conviction, is a principle basic to our society.”[65] This applies under international law.“Observing that due process is an evolutionary concept that takes into account accepted notions of fairness, and recognizing the fundamental principle that all human beings should be free from arbitrary detention.”[66] Or, in this matter, the taking of property in perpetuity.

  1. Analysis Article 12: Privacy

According to Article Twelve of the Universal Declaration of Human Rights, “No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks.”

United States Federal Courts have directly addressed this issue, and since the last time the Supreme Court of the United States has addressed this issue, the privacy analysis has changed substantially:

"In the vulnerable and embarrassing moments immediately after an individual is accused, taken into custody, and deprived of most liberties, fit squarely within this realm of embarrassing and humiliating information. More than just vivid symbols of criminal accusation, booking photos convey guilt to the viewer. Indeed, viewers so uniformly associate booking photos with guilt and criminality that we strongly disfavor showing such photos to criminal juries. The Sixth Circuit has condemned the practice of showing 'mug shot' evidence to a jury as effectively eliminating the presumption of innocence and replacing it with an unmistakable badge of criminality. This alone establishes a non-trivial privacy interest in booking photos.”[67]

Then we can easily draw the analytical chain to a multi-day jury using a basic google search to find a mugshot photo of accused persons on the internet. A mugshots mere image projects guilt on to the viewer, this is prejudicial conduct. Even without any evidentiary indication, a viewer is likely to perceive an accused as guilty even though they themselves may be the victim of a crime perpetuated by the local medically diagnosed insane person filing false police reports or law enforcement officers lack of reasonable diligence.

The international community wants states to protect individual privacy. “States are required to provide to every person the right to a judicial remedy for breach of privacy rights.”[68]  Photographs are data, it is biometric data that is yours as a human being.[69] In the U.S. a person can go and have their record expunged after a case has been found not guilty, nolle prosse or dismissed. The expungement process only has the effect of a Court file being destroyed. What it does not do, is get back the release of booking photos. The expungement remedy provided in the United States is defunct and mostly useless. Expungement solely means a Court file being destroyed, this process has limited effect.


Your name, image, likeness is your property. When we apply the Christian Biblical Worldview perspective to property interest, "You shall not covet your neighbor's… nor anything that is your neighbor's," it becomes clear that the Law of Nature and of Natures God, through scripture fully intended for humans not to infringe on that which is another humans.[70] To take something that is another humans without a full, fair and final hearing on a matter is not only contrary to the United States Constitution but also a direct affront to God’s law.

The scripture addresses infringement of dignity, “strength and dignity are her clothing, and she laughs at the time to come.”[71] “So God created man in his own image, in the image of God he created him; male and female he created them.”[72] God did not intend for humankind to degrade each other, and certainly not without proper cause. Let’s be clear, proper cause is not defined by  fleeting fickle current political opinion, or social media hysterical nonsense. Today’s practice of decimating a person that has not even been allowed a real opportunity to defend the accusations against them by releasing mugshots is against the Christian Biblical worldview.

So after examining the scripture related to dignity and property, God intended for humans to respect one another. The mugshot industry is contrary to that and thus contrary to God’s Law. Because, if God created humans in his image then he meant for his image through humans to be respected. Not only the property rights but also the more nuanced dignity rights. The injustice surrounding this practice is blatant. The law is not being used properly by releasing mugshots pre-hearing. This also breaks the social contract that we all have with each other and our government “the notion of agreement as the foundation of “just” or “legitimate” principles for governing society is the basis of the “social contract” tradition…” those in power are in breach of this contract.[73] Thus, accordingly this is not good law.

The United States Constitution was signed on September 17th, 1787. Since that day Jurisprudence has seen most of its protections muddled by Courts and Legislatures. We will continue our decent into tyranny controlled by those with malintent where the Constitutions basic principles mean nothing. Due Process of law is a basic principle that must not be diluted any longer. A small but at the same time significant secession from the powers that be incessant and generally cruel befuddlement of releasing their harassing photos is but little price to pay to make sure they are doing the right thing before they do it.



[1] Brett Samuels, Colin Powell: “We’ve come to live in a society based on insults, on lie,” The Hill, October, 31, 2018 at https://thehill.com/blogs/blog-briefing-room/414124-colin-powell-weve-come-to-live-in-a-society-based-on-insults-on-lies/

[2] Jason Kandel, Woman Who Falsely Accused Brian Banks of Rape Ordered to Pay $2.6M, June 15, 2013 at  https://www.nbclosangeles.com/news/local/woman-falsely-accused-brian-banks-rape-ordered-to-pay-26m/1971672/

[3] Ellie Cambridge, Joanne Kavanagh and Jennifer Roback, “Free Man” Where is O.J. Simpson now?, December 14, 2021 at https://www.the-sun.com/news/1586691/oj-simpson-who-where/

[4] Johnny McDevitt, Mugshot tabloids: defamation as the price for profitable 'schadenfreude'; Magazines access mugshots from police departments and print them for locals to see - but when they get it wrong, there are often little to no consequences. The Guardian. (September 4, 2016)

[5] Detroit Free Press, Inc. v. United States DOJ, 829 F.3d 482

[6] Washington v. Glucksberg, 521 U.S. 702, 728 (1997)

[7] Christina Locke and Bill F. Chamberlin, Safe from Sex Offenders? Legislating Internet Publication of Sex Offender Registries, The Urban Lawyer 39, no. 1 1–18 (Winter 2007).

[8] Tom Dart, Texas Governor Rick Perry has mugshot taken after indictment, The Guardian, (August 19, 2014) at https://www.theguardian.com/world/2014/aug/20/texas-governor-rick-perry-mugshot-indictment-rosemary-lehmberg; Heather Hamilton, WATCH: Ted Cruz Praises Twitter Files, says ‘Big Tech is losing their minds,’ Washington Examiner (February 14, 2023) at https://gazette.com/news/us-world/watch-ted-cruz-praises-twitter-files-says-big-tech-is-losing-their-minds/article_bf9b6c09-8185-55fe-96b5-18fe4ded06a2.html; David Malloy, Zuckerberg tells Rogan FBI warning prompted Biden laptop story censorship, BBC News (August 26, 2022) at https://www.bbc.com/news/world-us-canada-62688532

[9] Id.

[10] FBI National Press Office, FBI Releases 2020 Incident-based (NIBRS) Data, Federal Bureau of Investigation (December 6, 2021) at https://www.fbi.gov/news/press-releases/fbi-releases-2020-incident-based-data

[11] Chris Boyette and Zoe Sottile, San Francisco supervisors vote to allow police to use robots to kill, CNN (November 30, 2022) at https://www.cnn.com/2022/11/30/us/san-francisco-police-remote-control-robots/index.html

[12] George C. Christie, Injury to Reputation and the Constitution: Confusion Amid Conflicting Approaches, Michigan L. Rev. Vol. 75 No. 1 pp. 43-67 (November 1976).

[13] Id. at 53

[14] Id. at 59

[15] Mathews v. Eldridge, 424 U.S. 319, 334 (1976).

[16] Paul v. Davis, 424 U.S. 693 (1976)

[17] Kathryn Shephard, Mug Shot Disclosure Under FOIA: Does Privacy or Public Interest Prevail?, Northwestern Univ. L. R. Vol. 108, No. 1, 350 (2014).

[18] Id.

[19] Kathryn Shephard, Mug Shot Disclosure Under FOIA: Does Privacy or Public Interest Prevail?, Northwestern Univ. L. R. Vol. 108, No. 1, 353 (2014).

[20] Id.

[21] World Publ’g Co. v. United States DOJ, 672 F.3d 827, 2012.

[22] Id. at 828.

[23] CUS-SEP/OCT 01, pp. 48-50 and JCUS-SEP 03, pp. 15-16; Fed. R. App. P. 25(a), Fed. R. Bankr. P. 9037, Fed. R. Civ. P. 5.2, and Fed. R. Crim. P. 49.1.

[24] Supra, note 21 at 830.

[25] Belinda Palmada, Man’s life destroyed after woman falsely accused him of rape, News.com.au, (January 18, 2023) at https://www.news.com.au/world/europe/mans-life-destroyed-after-woman-falsely-accused-him-of-rape/news-story/9d5cd767fc69ab526c97d5cfd26cadc0

[26] Rachel Mahoney, Jury Finds Lynchburg Man Not Guilty Thursday, The News & Advance, (December 19, 2019); The Associated Press, After more than 70 years, 4 Black men wrongly accused of rape have been exonerated, NPR (November 22, 2021) at https://www.npr.org/2021/11/22/1058169726/groveland-four-exonerated; Cindy E. Rodriguez, Woman Who Falsely Accused Duke Lacrosse Players of Rape Charged With Stabbing Boyfriend, ABC News, (April 4, 2011) at https://abcnews.go.com/US/woman-accused-duke-lacrosse-team-members-rape-charged/story?id=13295161; Eugene J. Kanin, False Rape Allegations, Polygrah Vol. 30 Issue 3 163-171 (2001).

[27] Amendment 14, USCS Const. Amend. 14 (1868).

[28] Borger, John P., et al., RECENT DEVELOPMENTS IN MEDIA, PRIVACY, AND DEFAMATION LAW, Tort Trial & Insurance Practice Law Journal, vol. 39, no. 2 (2004)

[29] Loreto Corredoira, The Right of One’s Own Image in the Recent Cases of Sexual Harassment in Film Industry: Applying the European Theory of Concentric Circles to Celebrities (In Particular, Women), Journal of Information Policy, vol. 8, 384 (2018); Genesis 1:27 (King James)(“So God created man in his own image, in the image of God he created him; male and female he created them.”).

[30] Leonard G. Ratner, The Function of the Due Process Clause, University of Pennsylvania Law Review 116, no. 6 1048–1117 (1968).

[31] Kuckes, Niki. Civil Due Process, Criminal Due Process, pp.1-61Yale Law & Policy Review, vol. 25, no. 1, (Fall, 2006).

[32] Mathews v. Eldridge, 424 U.S. 319, 334 (1976).

[33] Id.

[34] Detroit Free Press, Inc. v. United States DOJ, 829 F.3d 478

[35] Amendment 6, USCS Const. Amend. 6 (1791).

[36] Paul v. Davis, 424 U.S. 693 (1976).

[37] David Cotriss, Keep It Clean: Social Media Screenings Gain in Popularity, Business News Daily (January 23, 2023) at https://www.businessnewsdaily.com/2377-social-media-hiring.html

[38] Alan Dershowitz, Guilt by Accusation: The Challenge of Proving Innocence in the Age of #MeToo, (Skyhorse Publishing, 2019); Karlyn Borysenko, The Dark Side of #MeToo: What Happens When Men Are Falsely Accused, Forbes (February 12, 2020) at https://www.forbes.com/sites/karlynborysenko/2020/02/12/the-dark-side-of-metoo-what-happens-when-men-are-falsely-accused/?sh=358cc6b0864d; Bianca Lallitto, 15 Shocking Cases of Cyberbullying That Led To Suicide, The Clever (August 15, 2017) at https://www.theclever.com/15-shocking-cases-of-cyberbullying-that-led-to-suicide/

[39] Borger, John P., et al., RECENT DEVELOPMENTS IN MEDIA, PRIVACY, AND DEFAMATION LAW” Tort Trial & Insurance Practice Law Journal, vol. 39, no. 2 (2004)

[40] Paul v. Davis, 424 U.S. 693 (1976)

[41] Roe v. Wade, 410 U.S. 113 (1973); Dobbs v. Jackson Women’s Health Organization,

945 F. 3d 265

[42] Harold J. Berman, Faith and Order, The Reconciliation of Law and Religion, p.12 (John Witte, Jr. 1993).

[43] Marbury v. Madison, 5 U.S. 137 (1803)

[44] Abner S. Greene, Checks and Balances in an Era of Presidential Lawmaking, The University of Chicago Law Review, vol. 61, no. 1, 123–96  (1994).

[45] Marbury v. Madison, 5 U.S. 137 (1803)

[46] Karantsalis v. United States DOJ, 635 F.3d 497, 2011; World Publ’g Co. v. United States DOJ, 672 F.3d 825, 2012; Times Picayune Publ'g. Corp. v. United States DOJ, 37 F. Supp. 2d 472, 477 (E.D. La. 1999).

[47] Hank Berrien, Oregon Prevents Release of Most Mugshots to Media, The Dailywire, (January 4, 2022)

[48] David Kravets, Mug-Shot Industry Will Dig Up Your Past Charge You to Bury It Again, Wired (August 2, 2011)

[49] Schmidt, Samantha, Owners of Mugshots.com accused of extortion: They attempted ‘to profit off of someone else’s humiliation, Washington Post (May 18, 2018) at https://www.chicagotribune.com/business/ct-biz-mugshot-website-owners-extortion-20180518-story.html

[50] § 8.01-45. Action for insulting words., Va. Code Ann. § 8.01-45 (Current through Chapter 22 of the 2022 Special Session I).

[51] Johnny McDevitt, Mugshot tabloids: defamation as the price for profitable 'schadenfreude'; Magazines access mugshots from police departments and print them for locals to see - but when they get it wrong, there are often little to no consequences. The Guardian. (September 4, 2016)

[52] Paul v. Davis, 424 U.S. 693, 697 (1976)

[53] Town & Country Properties v. Riggins, 249 Va. 387

[54] McDermott v. Reynolds, 260 Va. 98 at 101

[55] Christopher White, Automatic Booking Photo Disclosures: Dissociative Indifference to the Human Rights to Dignity, Due Process and Equality Under the Law, 6-13 (International Human Rights Law, Working Paper, May12, 2023)(The following section was predominately taken from a previous paper on the same subject but specifically international law).

[56] United Nations, Peace, Dignity and Equality on a Healthy Planet, (accessed March 9, 2023) at https://www.un.org/en/global-issues/human-rights.

[57] Mark 12:13-21 King James)

[58] Universal Declaration of Human Rights, Preamble, June 26, 1945, Stat. 1031 United Nations General Assembly.

[59] Paul v. Davis 424,  U.S. 693, 714 (1976)

[60]Stephanie Farrior Molding The Matrix: The Historical and Theoretical Foundations of International Law Concerning Hate Speech, 14 Berkeley J. Int'l L. 1, 14-15 (1996)

[61] Nicole R. Fleetwood, Racist Police Practices like mug shots normalize the criminalization of Black Americans, NBC, (August 6, 2020) at https://www.nbcnews.com/think/opinion/racist-police-practices-mug-shots-normalize-criminalization-black-americans-ncna1235694

[62] Kade Crockford, How is Face Recognition Surveillance Technology Racist? ACLU (June 16, 2020) at https://www.aclu.org/news/privacy-technology/how-is-face-recognition-surveillance-technology-racist

[63] Universal Declaration of Human Rights, December 10, 1948 ,United Nations General Assembly Resolution 217 A.

[64] Paul v. Davis, 424 U.S. 693, (1976) 714

[65] Anti-Fascist Committee v. McGrath, 341 U.S. 123 (1950), 168

[66] Gordon A. Christenson, Using Human Rights Law to Inform Due Process and Equal Protection Analyses, 51 U. Cin. L. Rev. 3 (1983)

[67] Detroit Free Press, Inc. v. United States DOJ, 829 F.3d 478, 482 (6th Cir. 2016)

[68] Council Directive 95/46, 1995 O.J. (L281) 31. at http://europa.eu.int/comm/dg15/en

[69] Glenn J. Voelz, The Rise of IWar: Identity, Information, and the Individualization of Modern Warfar,. Strategic Studies Institute, US Army War College, 119 (2015).

[70] Exodus 20:17 (King James).

[71] Proverbs 31:25 (King James).

[72] Genesis 1:27 (King James).

[73]  Brian H. Bix, Jurisprudence, Theory and Context, 114 (8th ed. 2019).


Thank you for reading,

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