Virginia Code

Va. Code Ann. § 18.2-21 (2026)

When and where accessories tried; how indicted

✓ current as of May 2026

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An accessory, either before or after the fact, may, whether the principal felon be convicted or not, or be amenable to justice or not, be indicted, tried, convicted and punished in the county or corporation in which he became accessory, or in which the principal felon might be indicted. Any such accessory before the fact may be indicted either with such principal or separately.

Code 1950, § 18.1-13; 1960, c. 358; 1975, cc. 14, 15.

Notes of Decisions

Cited in 6 cases, 1980–2019 · leading case: Redman v. Commonwealth, 487 S.E.2d 269 (Va. Ct. App. 1997).

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Redman v. Commonwealth, 487 S.E.2d 269 (Va. Ct. App. 1997). · cites it 2× “Although conviction of the principal is not a condition precedent to conviction of an accessory, Code § 18.2-21, conviction of an accessory requires proof that the crime has been committed by a principal.”

Dustin Scott Jones v. Commonwealth of Virginia, 826 S.E.2d 908 (Va. Ct. App. 2019). · cites it 2× “770, 771-72 (1980) (“Although conviction of a principal in the first degree is not a condition precedent to conviction of an accessory, Code § 18.2-21, before the accessory to a crime can be convicted as such, it must be shown that the crime has been committed by the principal.”

Standefer v. United States, 447 U.S. 10 (1980). “§ 609.05 (1978); Nev. Rev. Stat. § 195.040 (1979); Ohio Rev.”

State v. Petry, 273 S.E.2d 346 (W. Va. 1980). “274 § 3 (1970); Minn.Stat. § 609.05 (1964); Nev.Rev. Stat.”

Dusenbery v. Commonwealth, 263 S.E.2d 392 (Va. 1980). · cites it 2× “In felony cases, principals in the second degree and accessories before the fact are accountable “in all respects as if a principal in the first degree”. Code § 18.2-18. But, by definition, there can be no accessory without a principal.”

Grey Alexander Ferrell v. Commonwealth of Virginia, 743 S.E.2d 284 (Va. Ct. App. 2013). · cites it 2× “” Code § 18.2-21. The treatment of accessories, for preclusion purposes, now parallels the common law rule traditionally applicable only to principals in the second degree.”

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