Muhammad v. Commonwealth

John Allen Muhammad (defendant) and Lee Boyd Malvo fatally shot 11 people over a 47-day sniper spree, with Malvo always firing the actual shots from a hole cut into the trunk of Muhammad's specially modified car, while Muhammad supplied Malvo's rifle, drove him to each shooting location, personally spotted each victim, and directed Malvo on exactly when to fire. Virginia's death penalty was available only for first-degree, not second-degree, murder, and the jury convicted Muhammad of first-degree murder, resulting in a death sentence that he appealed.