Rose Ella Yarborough v. Commonwealth of Virginia

Summary

The court affirmed the voluntary-manslaughter conviction, holding that the defendant's intoxication did not render her post-warning statements involuntary because the evidence showed a knowing waiver and a rational, free choice. The court also held that the record supported the trial court's factual determination that the defendant failed to establish excusable homicide in self-defense, even though some trial-court comments reflected an erroneous legal theory. Because the conviction rested on a correct application of the law, the alternative error did not require reversal.