Va. Code » Title 18.2. Crimes and Offenses Generally » Chapter 7. Crimes Involving Health and Safety » Article 4. Dangerous Use of Firearms or Other Weapons
Virginia Code

Va. Code Ann. § 18.2-286.1 (2026)

Shooting from vehicles so as to endanger persons; penalty

✓ current as of May 2026
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Any person who, while in or on a motor vehicle, intentionally discharges a firearm so as to create the risk of injury or death to another person or thereby cause another person to have a reasonable apprehension of injury or death shall be guilty of a Class 5 felony. Nothing in this section shall apply to a law-enforcement officer in the performance of his duties.

1990, c. 951.

Notes of Decisions
Cited in 21 cases (10 in the last 5 years), 1995–2024 · leading case: Stephens v. Commonwealth, 557 S.E.2d 227 (Va. 2002).
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Stephens v. Commonwealth, 557 S.E.2d 227 (Va. 2002). · cites it 6× “2-154, and two counts of discharging a firearm while in a motor vehicle in violation of Code § 18.2-286.1. The jury found the defendant guilty of these crimes and fixed his punishment at a total of four years and 12 months imprisonment plus $2,000 in fines.”
Robert Lee Jones v. Commonwealth of Virginia, 808 S.E.2d 220 (Va. Ct. App. 2017). · cites it 10× “1 provides that “[a]ny person who, while in or on a motor vehicle, intentionally discharges a firearm so as to create the risk of injury or death to another person or thereby cause another person to have a reasonable apprehension of injury or death” commits a Class 5 felony.”
Stephens v. Commonwealth, 543 S.E.2d 609 (Va. Ct. App. 2001). · cites it 6× “2-154, and two counts of intentionally discharging a firearm from a motor vehicle so as *144 to create a risk of injury or death to another person or so as to cause another person to have a reasonable apprehension of injury or death, in violation of Code § 18.2-286.1. 1 He…”
State v. Tafoya, 2012 NMSC 30 (N.M. 2012). “”), andVa. Code § 18.2-286.1 (1990) (“Shooting From Vehicles So as to Endanger Persons” statute is violated when someone “while in or on a motor vehicle, intentionally discharges a firearm so as to create the risk of injury or death to another person .”
Marquay Christopher Alston, s/k/a Marquay Christopher Lee Alston v. Commonwealth of Virginia (Va. Ct. App. 2023). · cites it 16× “2, discharging a firearm from a vehicle in violation of Code § 18.2-286.1, and reckless handling of a firearm in violation of Code § 18.”
Jeffrey Allen Morris v. Commonwealth, 464 S.E.2d 169 (Va. Ct. App. 1995). · cites it 10× “Jeffrey Allen Morris was convicted of two counts of discharging a firearm from a motor vehicle so as to create the risk of injury or death to another person in violation of Code § 18.2-286.1. He contends that the evidence was insufficient to sustain the convictions.”
Jones v. Commonwealth, 821 S.E.2d 540 (Va. 2018). · cites it 14× “He also points to the existence of Code § 18.2-286.1, which makes it a felony to discharge a weapon while seated in a vehicle.”
Jerad Wyche-Alexander, a/k/a Jarad Wyche v. Commonwealth of Virginia (Va. Ct. App. 2023). · cites it 4× “2-154), discharging a firearm while in a vehicle (Code § 18.2-286.1), and possessing a firearm during the commission of a felony (Code § 18.”
Commonwealth v. Johnson, 68 Va. Cir. 482 (Nelson Cir. Ct. 2001). · cites it 4× “There are currently pending in this Court a charge of discharging a firearm from a motor vehicle in violation of § 18.2-286.1 and a charge of shooting at an occupied motor vehicle in violation of § 18.”
Anthony J. Slayton, s/k/a Anthony Jerome Slayton v. Commonwealth of Virginia (Va. Ct. App. 2022). · cites it 2× “2-154, and shooting from a vehicle in violation of Code § 18.2-286.1. Slayton asserts that the evidence presented at trial was insufficient to support the convictions.”
Lavishia Tia Fulton, s/k/a Lavisha Tia Fulton v. Commonwealth of Virginia (Va. Ct. App. 2023). · cites it 2× ““Whether an alternate hypothesis of innocence is reasonable is a question of fact and, therefore, is binding on appeal unless plainly 5 She does not challenge her conviction for shooting a firearm from a vehicle, in violation of Code § 18.2-286.1. -5- wrong.”6 Fary v.…”
Commonwealth of Virginia v. Rarmil Malick Coley Pettiford (Va. Ct. App. 2023). · cites it 2× “2-280(A); and discharging a firearm in a motor vehicle, in violation of Code § 18.2-286.1. The trial court granted the Commonwealth’s motion to try the five defendants jointly; however, for scheduling reasons, the case was split between the three defendants who did not waive…”
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