Virginia Code
Va. Code Ann. § 18.2-178.1 (2026)
Financial exploitation of vulnerable adults; penalty
✓ current as of May 2026
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A. As used in this section, "vulnerable adult" means the same as that term is defined in § 18.2-369.
B. It is unlawful for any person who knows or should know that another person is a vulnerable adult to, through the use of that other person's impairment, take, obtain, or convert money or other thing of value belonging to that other person with the intent to permanently deprive him thereof. Any person who violates this section shall be deemed guilty of larceny.
C. Venue for the trial of an accused charged with a violation of this section shall be in any county or city in which (i) any act was performed in furtherance of the offense, (ii) the accused resided at the time of the offense, (iii) the vulnerable adult resides or resided at the time of the offense, or (iv) the vulnerable adult sustained a financial loss as a result of the offense.
D. This section shall not apply to a transaction or disposition of money or other thing of value in which the accused acted for the benefit of the vulnerable adult or made a good faith effort to assist such person with the management of his money or other thing of value.
Notes of Decisions
Cited in 8
cases (6 in the last 5 years), 2014–2024 · leading case: Raymeka Monique White v. Commonwealth of Virginia, 807 S.E.2d 242 (Va. Ct. App. 2017).
Raymeka Monique White v. Commonwealth of Virginia, 807 S.E.2d 242 (Va. Ct. App. 2017). “Raymeka Monique White appeals her convictions for financial exploitation of a mentally incapacitated person and credit card fraud, in violation of Code §§ 18.2-178.1 and -195. The appellant argues that the Commonwealth failed to prove that the victim was mentally incapacitated…”
George Christopher Lilly v. Commonwealth of Virginia (Va. Ct. App. 2024). “Lilly appeals his five felony convictions for financially exploiting Randy, a “vulnerable adult” under Code § 18.2-178.1. Lilly argues that the Commonwealth failed to prove his guilt beyond a reasonable doubt.”
Catherine Ann Tomlin, a/k/a, etc. v. Commonwealth of Virginia (Va. Ct. App. 2022). “At its core, Tomlin’s argument is that evidence establishing B.T.’s mental incapacity with respect to her healthcare decisions cannot justify the trier of fact’s conclusion that her mental incapacity extended to financial matters.”
Delaney v. Virginia Dep't of Soc. Servs., Child Prot. Servs. (E.D. Va. 2024). “Plaintiffs first allege that individuals engaged in financial exploitation of their daughter Makayla, in violation of Va. Code Ann. § 18.2-178.1 . Compl. 23. That law protects “vulnerable adults” from financial exploitation through use of that vulnerable adult’s impairment.”
Spencer Kelly Dixon v. Commonwealth of Virginia (Va. Ct. App. 2021). “2-1075, and (2) obtained property by false pretenses under Code § 18.2-178.1 For the reasons stated below, we disagree and affirm the judgment of the trial court.”
Tomlin v. Commonwealth (Va. 2023). “The 1 Tomlin was also charged with and convicted of financial exploitation of an incapacitated adult under Code § 18.2-178.1. The Court of Appeals vacated the conviction on this count.”
Daniel Carlton Railey v. Commonwealth of Virginia (Va. Ct. App. 2024). “Daniel Carlton Railey appeals his conviction for obtaining money by false pretenses in violation of Code § 18.2-178.1 He contends that the evidence failed to prove he acted with the requisite intent to defraud.”
Robert Ray Crouch v. Commonwealth of Virginia (Va. Ct. App. 2014). “Robert Ray Crouch appeals his conviction of five counts of obtaining money by false pretenses, in violation of Code § 18.2-178.1 On appeal, Crouch argues that the trial court erred in failing to strike the evidence as to those charges because the Commonwealth allegedly failed to…”
— Va. Code Ann. § 18.2-178.1(A) — 2 cases
Raymeka Monique White v. Commonwealth of Virginia, 807 S.E.2d 242 (Va. Ct. App. 2017). “Raymeka Monique White appeals her convictions for financial exploitation of a mentally incapacitated person and credit card fraud, in violation of Code §§ 18.2-178.1 and -195. The appellant argues that the Commonwealth failed to prove that the victim was mentally incapacitated…”
Catherine Ann Tomlin, a/k/a, etc. v. Commonwealth of Virginia (Va. Ct. App. 2022). “At its core, Tomlin’s argument is that evidence establishing B.T.’s mental incapacity with respect to her healthcare decisions cannot justify the trier of fact’s conclusion that her mental incapacity extended to financial matters.”
— Va. Code Ann. § 18.2-178.1(B) — 1 case
George Christopher Lilly v. Commonwealth of Virginia (Va. Ct. App. 2024). “Lilly appeals his five felony convictions for financially exploiting Randy, a “vulnerable adult” under Code § 18.2-178.1. Lilly argues that the Commonwealth failed to prove his guilt beyond a reasonable doubt.”
— Va. Code Ann. § 18.2-178.1(D) — 3 cases
Raymeka Monique White v. Commonwealth of Virginia, 807 S.E.2d 242 (Va. Ct. App. 2017). “Raymeka Monique White appeals her convictions for financial exploitation of a mentally incapacitated person and credit card fraud, in violation of Code §§ 18.2-178.1 and -195. The appellant argues that the Commonwealth failed to prove that the victim was mentally incapacitated…”
Catherine Ann Tomlin, a/k/a, etc. v. Commonwealth of Virginia (Va. Ct. App. 2022). “At its core, Tomlin’s argument is that evidence establishing B.T.’s mental incapacity with respect to her healthcare decisions cannot justify the trier of fact’s conclusion that her mental incapacity extended to financial matters.”
George Christopher Lilly v. Commonwealth of Virginia (Va. Ct. App. 2024). “Lilly appeals his five felony convictions for financially exploiting Randy, a “vulnerable adult” under Code § 18.2-178.1. Lilly argues that the Commonwealth failed to prove his guilt beyond a reasonable doubt.”
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