Va. Code » Title 18.2. Crimes and Offenses Generally » Chapter 4. Crimes Against the Person » Article 1. Homicide
Virginia Code

Va. Code Ann. § 18.2-32.1 (2026)

Murder of a pregnant woman; penalty

✓ current as of May 2026
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The willful and deliberate killing of a pregnant woman without premeditation by one who knows that the woman is pregnant and has the intent to cause the involuntary termination of the woman's pregnancy without a live birth shall be punished by a term of imprisonment of not less than ten years nor more than forty years.

1997, c. 709.

Notes of Decisions
Cited in 8 cases (4 in the last 5 years), 2002–2024 · leading case: Johnson v. Commonwealth, 561 S.E.2d 1 (Va. Ct. App. 2002).
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Johnson v. Commonwealth, 561 S.E.2d 1 (Va. Ct. App. 2002). · cites it 2× “25 (bribery or gifts to state employees “with intent to influence said officer or employee in the discharge of any such duty”), Code § 18.2-32.1 (murder of a pregnant woman requires “the intent to cause the involuntary termination of the woman’s pregnancy”), Code § 18.”
Rashad v. Commonwealth, 651 S.E.2d 407 (Va. Ct. App. 2007). · cites it 2× “2-32) or murder of a pregnant woman (Code § 18.2-32.1). Categories of abduction include general abduction (Code § 18.”
Edward Leroy Marshall, Jr. v. Commonwealth of Virginia (Va. Ct. App. 2018). · cites it 2× “(“appellant”), appeals his conviction of second-degree murder, in violation of Code § 18.2-32.1 Following trial in the Circuit Court of Amherst County (“trial court”), the trial court imposed the jury’s recommended sentence of life imprisonment plus sixty-five years’…”
George Trevon Watson-Scott, a/k/a George T. Watson v. Commonwealth of Virginia (Va. Ct. App. 2018). · cites it 2× “George Trevon Watson-Scott (“appellant”) appeals his conviction for second-degree murder, in violation of Code § 18.2-32.1 He argues that the trial court erred in convicting him because the element of malice was absent.”
Raiquan Malique Sims v. Commonwealth of Virginia (Va. Ct. App. 2022). · cites it 2× “Raiquan Malique Sims challenges the sufficiency of the evidence supporting his conviction for first-degree murder, in violation of Code § 18.2-32.1 Concluding that sufficient evidence supports Sims’s conviction, we affirm.”
Martin Edenilson Flores v. Commonwealth of Virginia (Va. Ct. App. 2023). · cites it 2× “Flores contends on appeal that the trial court “[e]rred in [f]inding that the Commonwealth provided sufficient evidence in the form of premeditation and deliberation to support the indictment” for first-degree murder, in violation of Code § 18.2-32.1 Because Flores failed to…”
Calvin Elton Clark v. Commonwealth of Virginia (Va. Ct. App. 2023). · cites it 2× “Clark appeals his conviction, following a jury trial, for second-degree murder, in violation of Code § 18.2-32.1 Clark asserts that his Sixth Amendment right to confront witnesses was violated when a witness testified while wearing a mask and that the evidence is insufficient to…”
Karnell R. Pough, Jr. v. Commonwealth of Virginia (Va. Ct. App. 2024). · cites it 2× “(“appellant”) was convicted by a jury of second-degree murder, in violation of Code § 18.2-32.1 On appeal, appellant asserts that the trial court erred by: (1) denying his motion to strike because the evidence was insufficient to permit a rational fact finder to reject his claim…”
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