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jurisdictionappealhearingtrialplea
jurisdictionappealtrialpleagrand jury

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Holden v. Commonwealth, 26 Va.App. 403, 494 S.E.2d 892

Facts

Michael Richard Holden was indicted on multiple counts of forcible sodomy and aggravated sexual battery of children under thirteen. He entered a plea agreement where the court deferred judgment on two counts of aggravated sexual battery while sentencing him to ten years on the other two counts. The court required him to maintain good behavior, which included a prohibition against criminal activity. After prison officials seized letters from Holden advocating sexual abuse of children, the court held a hearing to determine if he violated the terms of his plea agreement.

On August 11, 1986, a grand jury indicted Holden on two counts of forcible sodomy and seven counts of aggravated sexual battery of children under the age of thirteen.

Issue

Did the trial court have jurisdiction to convict Holden on the deferred charges, and did his actions in prison violate the conditions of his plea agreement?

Holden contends first that the trial court lacked jurisdiction to convict him on the two counts of aggravated sexual battery as to which decision had been withheld.

Rule

Subject matter jurisdiction cannot be waived or conferred by agreement, and a trial court retains jurisdiction over deferred charges. Good behavior is not limited to the avoidance of criminal activity, and violations can occur through actions that advocate illegal conduct.

Subject matter jurisdiction is the authority granted a court to adjudicate a class of cases or controversies. Morrison v. Bestler, 239 Va. 166, 169, 387 S.E.2d 753, 755 (1990) . Subject *407 matter jurisdiction 'cannot be waived or conferred on the court by agreement of the parties.'

Analysis

The court determined that it had jurisdiction to adjudicate the deferred charges because the acceptance of the plea agreement did not divest it of that authority. The court found that Holden's actions in prison, specifically advocating sexual abuse of children, constituted a violation of the good behavior condition of his plea agreement. The court emphasized that good behavior encompasses more than just refraining from criminal activity.

Acceptance of Holden's plea agreement did not divest the trial court of its jurisdiction to adjudicate the charges. The legislature has granted subject matter jurisdiction to the circuit courts for all felonies and for 'all presentments, indictments and informations.'

Conclusion

The Court of Appeals affirmed the trial court's decision, concluding that Holden's misconduct justified the revocation of the deferred judgment and that the trial court acted within its jurisdiction.

Accordingly, we find no abuse of discretion in the trial court's decision to terminate the deferment of judgment.

Who won?

The Commonwealth prevailed in the case because the court upheld the trial court's findings that Holden violated the conditions of his plea agreement.

The Court of Appeals affirmed the trial court's decision, concluding that Holden's misconduct justified the revocation of the deferred judgment and that the trial court acted within its jurisdiction.

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