"Only when reasonable jurists could not differ can [this Court] say an abuse of discretion has occurred." Id. (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)). "[T]he abuse of discretion standard requires a reviewing court to show enough deference to a primary decisionmaker's judgment that the [reviewing] court does not reverse merely because it would have come to a different result in the first instance."

'"Only when reasonable jurists could not differ can we say an abuse of discretion has occurred."' Grattan v. Commonwealth, 278 Va. 602, 620, 685 S.E.2d 847, 861 (2009) (quoting Thomas v. Commonwealth, 44 Va. App. 741, 753, 607 S.E.2d 738, 743, adopted upon reh'g en banc, 45 Va. App. 811, 613 S.E.2d 870 (2005)). The highly deferential abuse-of-discretion standard of appellate review "means that the trial judge's ruling will not be reversed simply because an appellate court disagrees."

Judge Bellows accurately characterized the prevailing law in his memorandum decision, and it is clear that his refusal to recuse himself was not an abuse of discretion. See, e.g., Grattan v. Commonwealth, 278 Va. 602, 620, 685 S.E.2d 634, 644 (2009) (stating that a review for abuse of discretion “includes review to determine that the discretion was not guided by erroneous legal conclusions,” and finding no abuse of discretion where the trial judge's decision reflected proper application of governing legal principles). Prieto offered no evidence or even allegation of extrajudicial influence that would suggest bias.

" Carter v. Commonwealth, 293 Va. 537, 543 (2017) (first alteration in original) (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)).

Id. (quoting Grattan v. Commonwealth, 278 Va. 602, 620, 685 S.E.2d 634 (2009)). After defense counsel referred to Thomas as "developmentally delayed" during opening statements, the Commonwealth moved to exclude such evidence for lack of notice under Code § 19.2-271.6.

Id. (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)).

Rather, [this Court] consider[s] only whether the record fairly supports the trial court’s action.’" Carter v. Commonwealth, 293 Va. 537, 543, 800 S.E.2d 498 (2017) (alteration in original) (quoting Grattan v. Commonwealth, 278 Va. 602, 620, 685 S.E.2d 634 (2009)). [7–10] "The abuse-of-discretion standard [also] includes review to determine that the discretion was not guided by erroneous legal conclusions."

A reviewing court can conclude that "an abuse of discretion has occurred" only when "reasonable jurists could not differ" about the correct result. Commonwealth v. Swann, 290 Va. 194, 197 (2015) (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)). "This bell-shaped curve of reasonability" guiding appellate review

"Only when reasonable jurists could not differ can we say an abuse of discretion has occurred." Nottingham v. Commonwealth, 73 Va.App. 221, 231 (2021) (quoting Grattan v. Commonwealth, 278 Va. 602, 620 (2009)).

Rather, we consider only whether the record fairly supports the trial court's action." Grattan v. Commonwealth, 278 Va. 602, 620 (2009) (quoting Beck v. Commonwealth, 253 Va. 373, 385 (1997)). "Only when reasonable jurists could not differ