Walter Milton Correll, Jr. v. Commonwealth of Virginia; Walter Milton Correll, Jr. v. Commonwealth of Virginia

Summary

The Supreme Court of Virginia affirmed Walter Milton Correll, Jr.'s capital-murder conviction, robbery conviction, and sentence of death. The court held his confession admissible because, after invoking counsel, he initiated further dialogue by offering to explain his polygraph results and then knowingly and intelligently waived his rights despite an IQ of 68; the Commonwealth's failure to disclose the chief prosecution witness's petit larceny conviction was immaterial under Brady and Bagley; and the vileness findings of aggravated battery and depravity of mind were amply supported. The court also held that receipt of a presentence report satisfies Code § 19.2-264.5 in a bench trial, declined to reach the merits of ineffective-assistance claims concerning a continuance and a neurological examination, and found the death sentence neither arbitrary nor disproportionate.