Va. Code » Title 16.1. Courts Not of Record » Chapter 11. Juvenile and Domestic Relations District Courts » Article 9. Disposition
Virginia Code

Va. Code Ann. § 16.1-279 (2026)

Repealed

✓ laws through the 2026 session (checked Sept. 2026)
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Repealed by Acts 1991, c. 534.

Notes of Decisions
Cited in 18 cases, 1982–2020 · leading case: Pfoltzer v. Cnty. of Fairfax, 775 F. Supp. 874 (E.D. Va. 1991).
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Pfoltzer v. Cnty. of Fairfax, 775 F. Supp. 874 (E.D. Va. 1991). · cites it 8× “The order states in pertinent part: *890 [T]he Department has established by clear and convincing evidence that Lisa, Randy, Theresa and Christopher Morris are children in need of services within the meaning of Va.Code § 16.1-279(C) (Supp.1988) in that the condition of the…”
Martin v. Pittsylvania Cnty. Dep't of Soc. Servs., 348 S.E.2d 13 (Va. Ct. App. 1986). · cites it 2× “Those dispositional alternatives are initially found in Code § 16.1-279, and a final order of foster care placement had been entered.”
Church v. Church, 483 S.E.2d 498 (Va. Ct. App. 1997). · cites it 8× “" Thus, as part of the final decree, the court terminated father's residual parental rights, acting pursuant to former Code § 16.1-279(A). [1] The decree also eliminated father's obligation to provide child support and noted that mother "agreed to renounce any claim she may have…”
Grogg v. Commonwealth, 371 S.E.2d 549 (Va. Ct. App. 1988). · cites it 4× “1-272 the circuit court retains the discretion *607 to deal with the transferred child in the manner prescribed by Code § 16.1-279 for disposition of cases in the juvenile court, it is permissible for the circuit court to review the transcripts and written records from the…”
Jenkins v. Winchester Dep't of Soc. Servs., 409 S.E.2d 16 (Va. Ct. App. 1991). · cites it 2× “The finding of abuse and neglect was made pursuant to Code § 16.1-279 1 and is in no way affected by the foster care plan re *1184 quirements of Code § 16.”
Edwards v. Cnty. of Arlington, 361 S.E.2d 644 (Va. Ct. App. 1987). · cites it 4× “Code § 16.1-279(A) provides several alternative remedies less drastic than the termination of parental rights.”
Unknown Father v. Div. of Soc. Servs., 422 S.E.2d 407 (Va. Ct. App. 1992). · cites it 14× “2 Code § 16.1-279 was repealed effective July 1, 1991.”
Accomack Cnty. Dep't of Soc. Servs. v. Muslimani, 403 S.E.2d 1 (Va. Ct. App. 1991). · cites it 8× “Odum does not provide the standard by which a trial court should be guided in considering a motion to reopen a *225 case regarding the disposition of a child custody case under Code § 16.1-279. Except after sixty days from the date of an order committing a child to the…”
Norfolk Div. of Soc. Servs. v. Unknown Father, 345 S.E.2d 533 (Va. Ct. App. 1986). · cites it 2× “10 See, however, Code § 16.1-279(B): Where a parent. . . seeks to be relieved of the care and custody of any child pursuant to Subsection A 4 of § 16.”
Stanley v. Fairfax Cnty. Dep't of Soc. Servs., 405 S.E.2d 621 (Va. 1991). · cites it 2× “…grandmother. 3 The “disposition of a child” includes the court’s power to terminate residual parental rights. Code §§ 16.1-279(A)(5), -283.”
Grigg v. Commonwealth, 297 S.E.2d 799 (Va. 1982). · cites it 2× “Section 16.1-279(C)(2a) provides that, if a child is found in need of services, the court may “[o]rder the parent.”
Reid v. Reid, 409 S.E.2d 155 (Va. Ct. App. 1991). · cites it 2× “1 so as to include the phrase, “No support order may be retroactively modified, but may be modified with respect to any period during which there is a pending petition for modification, but only from the date that notice of such petition has been given to the responding party.”
Show all 18 citing cases →
Va. Code Ann. § 16.1-279(0): 1 case
Reid v. Reid, 409 S.E.2d 155 (Va. Ct. App. 1991). “1 so as to include the phrase, “No support order may be retroactively modified, but may be modified with respect to any period during which there is a pending petition for modification, but only from the date that notice of such petition has been given to the responding party.”
Va. Code Ann. § 16.1-279(A): 2 cases
Church v. Church, 483 S.E.2d 498 (Va. Ct. App. 1997). “" Thus, as part of the final decree, the court terminated father's residual parental rights, acting pursuant to former Code § 16.1-279(A). [1] The decree also eliminated father's obligation to provide child support and noted that mother "agreed to renounce any claim she may have…”
Edwards v. Cnty. of Arlington, 361 S.E.2d 644 (Va. Ct. App. 1987). “Code § 16.1-279(A) provides several alternative remedies less drastic than the termination of parental rights.”
Va. Code Ann. § 16.1-279(A)(5): 1 case
Stanley v. Fairfax Cnty. Dep't of Soc. Servs., 405 S.E.2d 621 (Va. 1991). “…grandmother. 3 The “disposition of a child” includes the court’s power to terminate residual parental rights. Code §§ 16.1-279(A)(5), -283.”
Va. Code Ann. § 16.1-279(B): 2 cases
Unknown Father v. Div. of Soc. Servs., 422 S.E.2d 407 (Va. Ct. App. 1992). “2 Code § 16.1-279 was repealed effective July 1, 1991.”
Norfolk Div. of Soc. Servs. v. Unknown Father, 345 S.E.2d 533 (Va. Ct. App. 1986). “10 See, however, Code § 16.1-279(B): Where a parent. . . seeks to be relieved of the care and custody of any child pursuant to Subsection A 4 of § 16.”
Va. Code Ann. § 16.1-279(B)(i): 1 case
Unknown Father v. Div. of Soc. Servs., 422 S.E.2d 407 (Va. Ct. App. 1992). “2 Code § 16.1-279 was repealed effective July 1, 1991.”
Va. Code Ann. § 16.1-279(C): 1 case
Pfoltzer v. Cnty. of Fairfax, 775 F. Supp. 874 (E.D. Va. 1991). “The order states in pertinent part: *890 [T]he Department has established by clear and convincing evidence that Lisa, Randy, Theresa and Christopher Morris are children in need of services within the meaning of Va.Code § 16.1-279(C) (Supp.1988) in that the condition of the…”
Va. Code Ann. § 16.1-279(C)(2a): 1 case
Grigg v. Commonwealth, 297 S.E.2d 799 (Va. 1982). “Section 16.1-279(C)(2a) provides that, if a child is found in need of services, the court may “[o]rder the parent.”
Va. Code Ann. § 16.1-279(F): 2 cases
Florence v. Roberts, 355 S.E.2d 316 (Va. 1987).
Winchester Med. Ctr., Inc. v. Giffin, 9 Va. Cir. 260 (Winchester Cir. Ct. 1987).
Va. Code Ann. § 16.1-279(O): 1 case
Reid v. Reid, 409 S.E.2d 155 (Va. Ct. App. 1991).
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