Virginia Code

Va. Code Ann. § 18.2-168 (2026)

Forging public records, etc

✓ current as of May 2026

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If any person forge a public record, or certificate, return, or attestation, of any public officer or public employee, in relation to any matter wherein such certificate, return, or attestation may be received as legal proof, or utter, or attempt to employ as true, such forged record, certificate, return, or attestation, knowing the same to be forged, he shall be guilty of a Class 4 felony.

Code 1950, § 18.1-92; 1960, c. 358; 1975, cc. 14, 15; 1976, c. 146.

Notes of Decisions

Cited in 67 cases (11 in the last 5 years), 1991–2025 · leading case: Campbell v. Commonwealth, 431 S.E.2d 648 (Va. 1993).

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Campbell v. Commonwealth, 431 S.E.2d 648 (Va. 1993). · cites it 32× “[7] See Va.Code Ann. § 18.2-168 (Repl.Vol.1988); Va.”

Campbell v. Commonwealth, 409 S.E.2d 21 (Va. Ct. App. 1991). · cites it 16× “Campbell, appellant, seeks reversal of his conviction of forging a public record in violation of Code § 18.2-168. He alleges that the trial court erred in refusing to instruct the jury that the crime had to be “to the prejudice of another” or to the gain of the defendant, and…”

Reid v. Commonwealth, 431 S.E.2d 63 (Va. Ct. App. 1993). · cites it 16× “Dexter Reid, appellant, also known as Gary Shaw, was convicted by the trial court under Code § 18.2-168, based on its finding that he gave the alias of Gary Shaw when arrested on September 10, 1991, and signed that same name, although misspelled as Gray, on his fingerprint card.”

Hines v. Commonwealth, 576 S.E.2d 781 (Va. Ct. App. 2003). · cites it 12× “Martin Levette Hines (appellant) was convicted in a bench trial of five counts of forging a public record, in violation of Code § 18.2-168. On appeal, he contends the trial court erred in convicting him of five counts of the offense when only one offense was committed.”

William Lloyd Henry v. Commonwealth of Virginia, 753 S.E.2d 868 (Va. Ct. App. 2014). · cites it 11× “William Lloyd Henry was convicted of two counts of forgery of a public record, two counts of uttering a forged public record, all in violation of Code § 18.2-168, and two counts of perjury in violation of Code § 19.”

Morgan Sinclair Goodwin v. Commonwealth of Virginia, 767 S.E.2d 741 (Va. Ct. App. 2015). · cites it 16× “Morgan Sinclair Goodwin appeals his three convictions for uttering a public record, in violation of Code § 18.2-168. He argues that the Commonwealth failed to present sufficient evidence to prove that he did anything other than sign three summonses with a false name.”

Sparrow v. Dir., Dep't of Corr., 439 F. Supp. 2d 584 (E.D. Va. 2006). · cites it 3× “See Va.Code § 18.2-168. At the subsequent bench trial, the government adduced expert evidence that the fingerprints on Jason’s 1999 fingerprint card matched those on the fingerprint card that Jason completed in October 2002 and signed with his brother’s name.”

Watts v. Commonwealth, 562 S.E.2d 699 (Va. Ct. App. 2002). · cites it 4× “James Edward Watts (Watts) was convicted in a Roanoke City Circuit Court bench trial of forging a public document in violation of Code § 18.2-168. He was sentenced to serve a term of eight months incarceration.”

Campbell v. Commonwealth, 421 S.E.2d 652 (Va. Ct. App. 1992). · cites it 4× “During Campbell's jury trial for forging a public record in violation of Code § 18.2-168, the jury was instructed as follows: JURY INSTRUCTION EIGHT To act with the intent to defraud means to act with an evil intent, or with the specific intent to deceive or trick.”

Edgar Edmundo Moreno v. Commonwealth of Virginia, 775 S.E.2d 422 (Va. Ct. App. 2015). · cites it 16× “Edgar Edmundo Moreno (appellant) appeals his conviction by a jury for uttering a forged public record in violation of Code § 18.2-168. Appellant argues that the circuit court erred in finding that a purported accord and satisfaction agreement, which appellant presented as…”

Bennett v. Commonwealth, 631 S.E.2d 332 (Va. Ct. App. 2006). · cites it 6× “In a bench trial, Ira Dale Bennett was convicted of uttering a forged public record in violation of Code § 18.2-168. On appeal, appellant challenges the sufficiency of the evidence to support his conviction.”

Welch v. Commonwealth, 425 S.E.2d 101 (Va. Ct. App. 1992). · cites it 4× “This conduct gave rise to the appellant's conviction for forging a public document in violation of Code § 18.2-168. This conviction is not the subject of this appeal.”

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