Virginia Code

Va. Code Ann. § 18.2-387 (2026)

Indecent exposure

✓ current as of May 2026

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Every person who intentionally makes an obscene display or exposure of his person, or the private parts thereof, in any public place, or in any place where others are present, or procures another to so expose himself, shall be guilty of a Class 1 misdemeanor. No person shall be deemed to be in violation of this section for breastfeeding a child in any public place or any place where others are present.

Code 1950, § 18.1-236; 1960, c. 233; 1975, cc. 14, 15; 1994, c. 398.

Notes of Decisions

Cited in 55 cases (9 in the last 5 years), 1985–2026 · leading case: Moses v. Commonwealth, 611 S.E.2d 607 (Va. Ct. App. 2005).

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Moses v. Commonwealth, 611 S.E.2d 607 (Va. Ct. App. 2005). · cites it 82× “Kenneth Samuel Moses challenges his conviction on two counts of making an obscene display or exposure in violation of Code § 18.2-387. Finding no error in the trial court's application of the statute to this case, we affirm.”

Simon v. Commonwealth, 708 S.E.2d 245 (Va. Ct. App. 2011). · cites it 15× “On appeal, he contends the trial court erred in refusing to instruct the jury on indecent exposure, proscribed by Code § 18.2-387, as a lesser-included offense.”

Hart v. Commonwealth, 441 S.E.2d 706 (Va. Ct. App. 1994). · cites it 28× “That statute provides that "[e]very person who intentionally makes an obscene display or exposure of his person, or the private parts thereof, in any public place ... shall be guilty of a Class 1 misdemeanor.”

Moyer v. Commonwealth, 531 S.E.2d 580 (Va. Ct. App. 2000). · cites it 12× “In Hart , the accused was charged and convicted of indecent exposure under Code § 18.2-387, which makes it a misdemeanor to "obscene[ly] display or expos[e]" ones "person, or the private parts thereof, in any public place.”

Viney v. Com., 609 S.E.2d 26 (Va. 2005). · cites it 4× “Viney and the Commonwealth agree that only one of the four factors mentioned in McKeon is at issue in this case: that the defendant made gestures toward himself or to the child.”

Leo Ricardo Barnes v. Commonwealth of Virginia, 737 S.E.2d 919 (Va. Ct. App. 2013). · cites it 14× “Leo Ricardo Barnes (appellant) appeals his convictions for indecent exposure, in violation of Code §§ 18.2-387 and 18.2-67.5:1, and for sexual display, in violation of Code § 18.”

Moses v. Commonwealth, 600 S.E.2d 162 (Va. Ct. App. 2004). · cites it 83× “2-370, and two misdemeanor counts of making an obscene display or exposure of his person in violation of Code § 18.2-387. Moses contends the evidence was insufficient to support the misdemeanor convictions.”

Boyd v. Cnty. of Henrico, 592 S.E.2d 768 (Va. Ct. App. 2004). · cites it 4× “[17] The County correctly notes that breast feeding is statutorily exempted from the indecent exposure statute, so no prosecution could follow under state Code § 18.2-387. Nevertheless, breast feeding would be what the Commonwealth's Attorney described as a "technical" violation…”

Crislip v. Commonwealth, 554 S.E.2d 96 (Va. Ct. App. 2001). · cites it 6× “1-100 with the term “in public” under Code § 18.2-388.”

United States v. Statler, 121 F. Supp. 2d 925 (E.D. Va. 2000). · cites it 15× “§ 13 , to support a charge under the Virginia indecent exposure statute, Va.Code § 18.2-387, for the same conduct.”

Morales v. Commonwealth, 525 S.E.2d 23 (Va. Ct. App. 2000). · cites it 10× “On appeal from his convictions of indecent exposure, in violation of Code § 18.2-387, and peeping into a dwelling, in *543 violation of Code § 18.”

Wilson v. Commonwealth, 615 S.E.2d 500 (Va. Ct. App. 2005). · cites it 2× “4, and indecent exposure, in violation of Code § 18.2-387. On appeal, Wilson challenges the sufficiency of the evidence to support his convictions, also contending that the trial court erroneously admitted a letter that the victim wrote to her grandmother because the victim’s…”

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