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Nathaniel Junius Boyd-Goode v. Commonwealth of Virginia

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Summary

The Virginia Court of Appeals affirmed a trial court judgment convicting Nathaniel Junius Boyd-Goode of possession of a firearm by a convicted violent felon under Virginia Code § 18.2-308.2. The appellate court upheld the five-year incarceration sentence after finding sufficient evidence, including Boyd-Goode's admission of ownership of the rifle. The appellant's claim that the evidence was insufficient to prove the rifle was a firearm was deemed waived under Rule 5A:18.

What changed

The Virginia Court of Appeals affirmed the conviction of Boyd-Goode for possession of a firearm by a convicted violent felon. The court found sufficient evidence to support the conviction, including the defendant's admission of ownership of a rifle. The defendant's argument that the evidence was insufficient to prove the rifle qualified as a firearm was waived for failure to present the argument to the trial court under Rule 5A:18.

Legal professionals and criminal defense attorneys should note that appellate courts will strictly enforce procedural waivers under Rule 5A:18 when arguments are not raised at trial. The case reinforces that a defendant's own admission can constitute sufficient evidence for firearm possession charges. Government agencies and law enforcement should ensure proper documentation at trial to withstand sufficiency challenges on appeal.

What to do next

  1. Review firearm possession statutes for compliance
  2. Update internal policies on prohibited persons firearm possession

Penalties

Five years incarceration

Archived snapshot

Apr 8, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

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April 7, 2026 Get Citation Alerts Download PDF Add Note

Nathaniel Junius Boyd-Goode v. Commonwealth of Virginia

Court of Appeals of Virginia

  • Citations: None known
  • Docket Number: 1777242
  • Precedential Status: Non-Precedential
  • Disposition: Judgment affirmed as trial court did not err finding evidence sufficient to convict appellant of possession of firearm by convicted violent felon; evidence established appellant admitted ownership of rifle; claim of insufficient evidence to prove rifle a firearm waived, Rule 5A:18

  • Opinion

  • Authorities (8)

  • Cited By (0)

  • Summaries (0)

  • Similar Cases (23.2K)

  • PDF

Disposition

Judgment affirmed as trial court did not err finding evidence sufficient to convict appellant of possession of firearm by convicted violent felon; evidence established appellant admitted ownership of rifle; claim of insufficient evidence to prove rifle a firearm waived, Rule 5A:18

Combined Opinion

COURT OF APPEALS OF VIRGINIA

Record No. 1777-24-2

NATHANIEL JUNIUS BOYD-GOODE
v.
COMMONWEALTH OF VIRGINIA

Present: Judges Causey, Chaney and White
Opinion Issued April 7, 2026*

FROM THE CIRCUIT COURT OF MECKLENBURG COUNTY
S. Anderson Nelson, Judge

(Alanna Meek, Assistant Public Defender, on brief), for appellant.

(Jason S. Miyares,1 Attorney General; Kelly L. Sturman, Assistant Attorney General, on brief), for
appellee.

MEMORANDUM OPINION
PER CURIAM

Sitting without a jury, the trial court found Nathaniel Junius Boyd-Goode guilty of

possession of a firearm by a convicted violent felon in violation of Code § 18.2-308.2. The court

sentenced Boyd-Goode to five years of incarceration. On appeal, Boyd-Goode argues that the

evidence was insufficient to support the conviction. For the following reasons, we affirm.2

*
This opinion is not designated for publication. See Code § 17.1-413(A).
1
Jay C. Jones succeeded Jason S. Miyares as Attorney General on January 17, 2026.
2
Having examined the briefs and record in this case, the panel unanimously agrees that
oral argument is unnecessary because “the dispositive issue or issues have been authoritatively
decided, and the appellant has not argued that the case law should be overturned, extended,
modified, or reversed.” See Code § 17.1-403(ii)(b); Rule 5A:27(b).
BACKGROUND3

On August 4, 2021, Corporal Josh Watts was on routine patrol in Mecklenburg County

when he received a call to report to Winston Johnson’s residence for a welfare check. At the

residence, Watts noticed a white vehicle in the yard with “a couple [of] bullet holes.” Watts

inspected the vehicle and observed an “AR-15 style rifle” in plain view in the backseat. Johnson

told Watts that Boyd-Goode owned the vehicle. Watts then spoke with Boyd-Goode, who

confirmed that he owned the car and that he had purchased it from his cousin.4 In addition,

Boyd-Goode told Watts he owned the rifle and that he was a convicted felon.5

At trial, however, Boyd-Goode testified that Johnson owned the vehicle and the firearm.

He claimed that he had planned to purchase the vehicle but never did and that only Johnson

possessed a set of keys. Boyd-Goode stated he had “no idea” why he told the officers the vehicle

and firearm belonged to him. On cross-examination, he testified that the officers had woken him

up, so he “might have gotten little things confused.”

The trial court rejected Boyd-Goode’s testimony and found him guilty of possession of a

firearm by a convicted violent felon. This appeal followed.

3
We recite the facts “in the ‘light most favorable’ to the Commonwealth, the prevailing
party in the trial court.” Hammer v. Commonwealth, 74 Va. App. 225, 231 (2022) (quoting
Commonwealth v. Cady, 300 Va. 325, 329 (2021)). In doing so, we discard any evidence that
conflicts with the Commonwealth’s evidence, and regard as true all the credible evidence
favorable to the Commonwealth and all inferences that can be fairly drawn from that evidence.
Cady, 300 Va. at 329.
4
During cross-examination, Watts reiterated that Boyd-Goode “stated the vehicle was
his” and that he did not “check and find out whether or not it was registered.”
5
At trial, the Commonwealth presented evidence of Boyd-Goode’s prior felony
conviction.
-2-
ANALYSIS

“When an appellate court reviews the sufficiency of the evidence underlying a criminal

conviction, its role is a limited one.” Commonwealth v. Garrick, 303 Va. 176, 182 (2024). “The

judgment of the trial court is presumed correct and will not be disturbed unless it is ‘plainly wrong

or without evidence to support it.’” Pijor v. Commonwealth, 294 Va. 502, 512 (2017) (quoting

Code § 8.01-680). “Thus, ‘it is not for this [C]ourt to say that the evidence does or does not

establish [the defendant’s] guilt beyond a reasonable doubt because as an original proposition it

might have reached a different conclusion.’” Commonwealth v. Barney, 302 Va. 84, 97 (2023)

(alterations in original) (quoting Cobb v. Commonwealth, 152 Va. 941, 953 (1929)).

The only relevant question for this Court on review “is, after reviewing the evidence in the

light most favorable to the prosecution, whether any rational trier of fact could have found the

essential elements of the crime beyond a reasonable doubt.” Id. (quoting Sullivan v.

Commonwealth, 280 Va. 672, 676 (2010)). “If there is evidentiary support for the conviction, ‘the

reviewing court is not permitted to substitute its own judgment, even if its opinion might differ from

the conclusions reached by the finder of fact at the trial.’” McGowan v. Commonwealth, 72

Va. App. 513, 521 (2020) (quoting Chavez v. Commonwealth, 69 Va. App. 149, 161 (2018)).

Boyd-Goode first asserts that the evidence was insufficient to prove that the rifle was a

firearm by definition. But Boyd-Goode never made this argument in the trial court, and any such

argument on appeal is barred by Rule 5A:18.6 Although Rule 5A:18 contains exceptions for good

6
“No ruling of the trial court . . . will be considered as a basis for reversal unless an
objection was stated with reasonable certainty at the time of the ruling, except for good cause shown
or to enable this Court to attain the ends of justice.” Rule 5A:18. “The purpose of this
contemporaneous objection requirement is to allow the trial court a fair opportunity to resolve the
issue at trial, thereby preventing unnecessary appeals and retrials.” Creamer v. Commonwealth, 64
Va. App. 185, 195
(2015).
-3-
cause or to meet the ends of justice, Boyd-Goode has not invoked either exception, and we do

not consider them sua sponte. Spanos v. Taylor, 76 Va. App. 810, 827-28 (2023).

It is unlawful for “any person who has been convicted of a felony . . . to knowingly and

intentionally possess or transport any firearm or ammunition for a firearm.” Code

§ 18.2-308.2(A). “Possession can be either actual or constructive.” Garrick, 303 Va. at 183.

“Determining the credibility of witnesses . . . is within the exclusive province of the [fact

finder], which has the unique opportunity to observe the demeanor of the witnesses as they

testify.” Welch v. Commonwealth, 79 Va. App. 760, 767 (2024) (alterations in original) (quoting

Dalton v. Commonwealth, 64 Va. App. 512, 526 (2015)). “In its role of judging witness

credibility, the fact finder is entitled to disbelieve the self-serving testimony of the accused and

to conclude that the accused is lying to conceal his guilt.” Flanagan v. Commonwealth, 58

Va. App. 681, 702 (2011) (quoting Marable v. Commonwealth, 27 Va. App. 505, 509-10

(1998)).

Without disputing his prior conviction for a felony, Boyd-Goode argues that the evidence

was insufficient to prove that he possessed the rifle. He maintains that Johnson owned and had

exclusive possession of the vehicle and the firearm and reiterates that he “might have gotten little

things confused” when speaking with the officers.

The trial court rejected Boyd-Goode’s testimony, finding it completely “at odds” with

what he told the officers. The evidence established that Boyd-Goode admitted that he owned

both the vehicle and the rifle found in the backseat. The evidence was therefore sufficient to

prove beyond a reasonable doubt that Boyd-Goode possessed the firearm and that he was guilty

of violating Code § 18.2-308.2.

-4-
CONCLUSION

For the foregoing reasons, we affirm the trial court’s judgment.

Affirmed.

-5-

Named provisions

Code § 18.2-308.2 Rule 5A:18

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Last updated

Classification

Agency
VA Court of Appeals
Filed
April 7th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Substantive
Document ID
Record No. 1777-24-2
Docket
1777242

Who this affects

Applies to
Criminal defendants Law enforcement Government agencies
Industry sector
9211 Government & Public Administration
Activity scope
Firearm possession prosecution Criminal appeals Sentencing
Geographic scope
Virginia US-VA

Taxonomy

Primary area
Criminal Justice
Operational domain
Legal
Topics
Firearms Regulation

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