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. § 16.1-289 (2026)

Review of order of commitment

✓ current as of May 2026
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The juvenile court or the circuit court, as the case may be, of its own motion may reopen any case and may modify or revoke its order. The juvenile court or the circuit court shall before modifying or revoking such order grant a hearing after notice in writing to the complainant, if any, and to the person or agency having custody of the child; provided, however, that this section shall not apply in the case of a child committed to the Department after sixty days from the date of the order of commitment.

Code 1950, § 16.1-183; 1956, c. 555; 1977, c. 559.

Notes of Decisions
Cited in 10 cases, 1991–2013 · leading case: Richardson v. Commonwealth, 504 S.E.2d 884 (Va. Ct. App. 1998).
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Richardson v. Commonwealth, 504 S.E.2d 884 (Va. Ct. App. 1998). · cites it 10× “George William Richardson contends that the trial court erroneously dismissed as untimely his appeal from a juvenile court’s judgment in a commitment review hearing held pursuant to Code § 16.1-289. For the reasons that follow, we reverse and remand the case to the trial court.”
Austin v. Commonwealth, 590 S.E.2d 68 (Va. Ct. App. 2003). · cites it 2× “Pursuant to Code § 16.1-289, Austin timely appealed this juvenile court order to the Franklin County Circuit Court.”
Patricia Blevins v. Prince William Cnty. Dep't of Soc. Servs., 733 S.E.2d 674 (Va. Ct. App. 2012). · cites it 2× “1-296(A) (“[OJrders entered pursuant to 16.1-278.2 are final orders from which an appeal may be taken.”
Accomack Cnty. Dep't of Soc. Servs. v. Muslimani, 403 S.E.2d 1 (Va. Ct. App. 1991). · cites it 2× “Code § 16.1-289. The overarching concern in all custody cases is the best interests of the child.”
Hedge Everett Washington, Jr. v. Commonwealth (Va. Ct. App. 2007). · cites it 14× “The sole issue presented by this appeal is whether the trial judge had the authority under Code § 16.1-289 to modify an order, which committed a juvenile to the Department of Juvenile Justice and simultaneously scheduled a hearing for review of the order, more than sixty days…”
Commonwealth v. Giles, 87 Va. Cir. 320 (Roanoke County Cir. Ct. 2013). · cites it 13× “In turn, the Commonwealth asks the Court to void the Juvenile Court’s setting of an appeal bond at the September 25 hearing because that court lacked jurisdiction over the matter pursuant to Va. Code § 16.1-289. For the reasons that follow, the Court finds that this case is…”
Jeremy Antonio Washington v. Commonwealth of Virginia (Va. Ct. App. 2011). · cites it 12× “In a letter to the parties, the judge stated that after the hearing, he realized that Code § 16.1-289 allowed for review, but only within sixty days.”
Marquis D. Edmonds v. Commonwealth of Virginia (Va. Ct. App. 2013). · cites it 4× “On appeal, Edmonds argues that the trial court erred in revoking his previously suspended adult sentence because the court did not have jurisdiction to modify the original sentencing order, rendering the order void, for three different reasons: (1) the court was precluded by…”
Commonwealth v. T.W.L., 34 Va. Cir. 534 (Amherst Cir. Ct. 1993). · cites it 3× “Michael Gamble Under Issue II of its order of May 19, 1993, the Juvenile and Domestic Relations District Court of Amherst County declined to reopen this case under the provisions of § 16.1-289 of the Code of Virginia. Under the provisions of § 16.”
Fairfax Cnty. Dep't of Fam. Servs. v. Doe, 54 Va. Cir. 18 (Fairfax Cir. Ct. 2000). “Indeed, the September 8, 1999, order and the transcript from the December 13, 1999, hearing indicate that the court was not motivated by á concern for Brittany Smoot’s best interests, but rather by concerns regarding Christopher Moore’s relationship with his guardian ad litem…”
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