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Virginia Code

Va. Code Ann. § 1-234 (2026)

Personal representative

✓ current as of May 2026
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"Personal representative" includes the executor of a will or the administrator of the estate of a decedent, the administrator of such estate with the will annexed, the administrator of such estate unadministered by a former representative, whether there is a will or not, any person who is under the order of a circuit court to take into his possession the estate of a decedent for administration, and every other curator of a decedent's estate, for or against whom suits may be brought for causes of action that accrued to or against the decedent.

Code 1919, § 5; Code 1950, § 1-13; 1950, p. 22, § 1-13.21; 1971, Ex. Sess., c. 49; 2005, c. 839.

Notes of Decisions
Cited in 11 cases (7 in the last 5 years), 2009–2026 · leading case: In re: Woodley, 777 S.E.2d 560 (Va. 2015).
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In re: Woodley, 777 S.E.2d 560 (Va. 2015). · cites it 4× “Under the Death by Wrongful Act Statute, the personal representative of the decedent plays a pivotal role.”
Reineck v. Lemen, 792 S.E.2d 269 (Va. 2016). · cites it 2× “Under Code §§ 1-234 and 64.2-100 the General Assembly has adopted the general term "[p]ersonal representative" to encompass executors, administrators of an estate, and every other person who serves as a curator of a decedent's estate.”
Est. of Eleusipa Van Emburgh v. United States, 95 F.4th 795 (4th Cir. 2024). “2015) (citing Va. Code Ann. § 1-234 ). A person named in a will as executor cannot “exercise the powers of executor until he qualifies as such” in court.”
In re: Woodley (Va. 2015). · cites it 4× “1808), the English common law case relied upon for the statement that wrongful death actions were disallowed, “was based on neither precedent nor logic”). 5 See, e.g., Code § 8.”
Platt v. Griffith (Va. 2021). · cites it 2× “1020, 1028 (1980)); see also Code § 1-234; cf. Campbell v. Harmon, 271 Va.”
Phillips v. Rohrbaugh (Va. 2021). · cites it 2× “Phillips nevertheless contends that she fits within a narrow exception to the general rule that enables certain beneficiaries to serve as ad hoc representatives of an estate under special circumstances.”
Kittrell v. Fowler (ORDER) (Va. 2022). · cites it 2× “Appellees further theorize that because they were the ultimate remainder beneficiaries of Margaret’s Living Trust, they would have received Margaret’s minority interest in Hurley, LLC upon her death.”
Taylor v. AIDS-Hilfe Koln e.V. (Va. 2022). · cites it 2× “See Code § 1-234. 6 Act, by its terms, applies only when a foreign court has “[g]rant[ed] or denie[d] recovery of a sum of money.”
Stavros P. Galiotos, Individually v. Tasos A. Galiotos, Individually (Va. Ct. App. 2026). · cites it 2× “Smith also argues that the circuit court was permitted to include the finding regarding her conduct in the final order because in her complaint/petition, she asked for “such further relief as this [c]ourt may deem just and prudent.”
Rodriguez v. N. Virginia Elec. Coop., 79 Va. Cir. 266 (Loudoun Cir. Ct. 2009). · cites it 3× “The definition of “personal representative” in Va. Code § 1-234 includes an administrator.”
Kuiper v. Mena (E.D. Va. 2025). “§ 1-234. Because this would leave Plaintiff without a remedy, the Court then turns again to the law of El Salvador.”
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