Virginia Code
Va. Code Ann. § 18.2-387.1 (2026)
Obscene sexual display; penalty
✓ current as of May 2026
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Any person who, while in any public place where others are present, intending that he be seen by others, intentionally and obscenely as defined in § 18.2-372, engages in actual or explicitly simulated acts of masturbation, is guilty of a Class 1 misdemeanor.
2005, c. 422.
Notes of Decisions
Cited in 5
cases (3 in the last 5 years), 2013–2026 · leading case: Leo Ricardo Barnes v. Commonwealth of Virginia, 737 S.E.2d 919 (Va. Ct. App. 2013).
Leo Ricardo Barnes v. Commonwealth of Virginia, 737 S.E.2d 919 (Va. Ct. App. 2013). “5:1, and for sexual display, in violation of Code § 18.2-387.1. On appeal, he argues that the evidence was insufficient to support his convictions because appellant was not “in public” or “in any public place” at the time of the alleged offenses.”
James David Hazelwood v. Commonwealth of Virginia (Va. Ct. App. 2026). “PUBLISHED OPINION BY JUDGE DAVID BERNHARD James David Hazelwood appeals the circuit court’s denial of his motion to strike two counts of obscene sexual display (Code § 18.2-387.1), and three counts of violation of a protective order (Code § 18.”
Samuel Harris, s/k/a Samuel Harris, Jr. v. Commonwealth of Virginia (Va. Ct. App. 2025). “In this case of first impression, we address the question of whether Code § 18.2-387.1 permits multiple convictions for a single “actual or explicitly simulated act[] of masturbation.”
Devonza A. Johnson, Sometimes Known as Devonza Antiwan Johnson v. Commonwealth of Virginia (Va. Ct. App. 2022). “Devonza Antiwan Johnson appeals his conviction for engaging in an obscene sexual display in violation of Code § 18.2-387.1. While incarcerated in the restrictive housing unit at the Augusta Correctional Center, Johnson called a female prison librarian over to the window of his…”
Davis v. Davis, 89 Va. Cir. 90 (Norfolk Cir. Ct. 2014). “2-387, and obscene sexual display, Va. Code § 18.2-387.1, when the *93 defendant was masturbating in his cell block in jail, a place most members of the public hope never to be.”
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