A person convicted of a felony or perjury should not be incompetent to testify, but the fact of conviction may be shown to affect his credit. Only a conviction, not a revocation of probation, may be used to impeach the credibility of a witness. Although no general constitutional right to discovery exists in a criminal case in this Commonwealth, due process requires that the prosecution produce evidence favorable to the accused upon request when that evidence is material either to guilt or punishment. Disclosure is required only if the evidence is both favorable to the accused and material either to guilt or to punishment. 8 Va. App.
Evidence is material either to guilt or to punishment .
Because the conditions of probation and probation revocation order that Willis sought could not have been used by him to impeach Harvey, that information was not material and was not a proper subject of discovery. The judgment of the trial court is affirmed.