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HOWARD v. COMMONWEALTH

Record No. 0495-21-4.

872 S.E.2d 212 (2022)

74 Va. App. 739

Jeffery Dale HOWARD v. COMMONWEALTH of Virginia.

Court of Appeals of Virginia, Fairfax.

May 10, 2022.

Attorney(s) appearing for the Case

J. Austin Timberlake , Senior Assistant Public Defender, for appellant.

Liam A. Curry , Assistant Attorney General ( Jason S. Miyares , Attorney General; Leah A. Darron , Senior Assistant Attorney General, on brief), for appellee.

Present: Chief Judge Decker, Judges Ortiz and Causey.

Jeffery Dale Howard ("Howard") appeals his conviction in the Stafford County Circuit Court of threatening to burn or bomb a means of transportation under Code § 18.2-83(A). On appeal, Howard assigns error on four grounds: (I) the circuit court erred in joining the assault and battery charge with the threatening...

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