Va. Code » Title 18.2. Crimes and Offenses Generally » Chapter 10. Crimes Against the Administration of Justice » Article 5. Contempt of Court
Virginia Code

Va. Code Ann. § 18.2-457 (2026)

Fine and imprisonment by court limited unless jury impaneled

✓ current as of May 2026
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No court shall, without a jury, for any such contempt as is mentioned in the first class embraced in § 18.2-456, impose a fine exceeding $250 or imprison more than ten days; but in any such case the court may, without an indictment, information or any formal pleading, impanel a jury to ascertain the fine or imprisonment proper to be inflicted and may give judgment according to the verdict.

Code 1950, § 18.1-295; 1960, c. 358; 1975, cc. 14, 15; 1999, c. 626.

Notes of Decisions
Cited in 23 cases (6 in the last 5 years), 1982–2025 · leading case: Nusbaum v. Berlin, 641 S.E.2d 494 (Va. 2007).
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Nusbaum v. Berlin, 641 S.E.2d 494 (Va. 2007). · cites it 8× “2-456(1) and imposed a fine of $250 pursuant to Code § 18.2-457. Nusbaum petitioned for an appeal to this Court pursuant to Code § 8.”
George M. Epps, Sheriff of City of Petersburg, Virginia v. Commonwealth, 626 S.E.2d 912 (Va. Ct. App. 2006). · cites it 6× “Appellant was not entitled to a jury because the Commonwealth proceeded under Code § 18.2-457, which allows punishment of no more than ten days in jail.”
Baugh v. Commonwealth, 417 S.E.2d 891 (Va. Ct. App. 1992). · cites it 8× “" Code § 18.2-457. As defendant's sentence was comported with Code § 18.”
Scialdone v. Commonwealth, 660 S.E.2d 317 (Va. Ct. App. 2008). · cites it 8× “Pursuant to Code § 18.2-457, "No court shall, without a jury, for any such contempt [under Code § 18.”
Epps v. Commonwealth, 616 S.E.2d 67 (Va. Ct. App. 2005). · cites it 4× “Appellant was not entitled to a jury because the Commonwealth proceeded under Code § 18.2-457, which allows punishment of no more than ten days in jail.”
Jud. Inq. & Review Com'n v. Peatross, 611 S.E.2d 392 (Va. 2005). · cites it 2× “The same is true with regard to the charge that Judge Peatross had a policy that he would not try misdemeanor charges unless they were companion cases to a felony charge against the same defendant.”
Brown v. Commonwealth, 497 S.E.2d 147 (Va. Ct. App. 1998). · cites it 2× “Where punishment is by fine and *763 determined without a jury, Code § 18.2-457 limits the sum to no more than $50.”
The Cura Grp., Inc. v. Virginia Workers' Comp. Comm'n, 612 S.E.2d 735 (Va. Ct. App. 2005). · cites it 6× “See Code § 18.2-457; Yoder v. Commonwealth, 107 Va.”
Paul A. Galiotos, Individually v. Tasos A. Galiotos, Individually (Va. Ct. App. 2025). · cites it 6× “Paul’s claims under Code § 18.2-457 Paul claims that the September 5, October 27, and January 29 contempt orders violated Code § 18.”
Paul A. Galiotos, Individually v. Tasos A. Galiotos, Individually (Va. Ct. App. 2025). · cites it 6× “Paul’s claims under Code § 18.2-457 Paul claims that the September 5, October 27, and January 29 contempt orders violated Code § 18.”
Paul A. Galiotos, Individually v. Tasos A. Galiotos, Individually (Va. Ct. App. 2025). · cites it 6× “Paul’s claims under Code § 18.2-457 Paul claims that the September 5, October 27, and January 29 contempt orders violated Code § 18.”
Paul A. Galiotos, Individually v. Tasos A. Galiotos, Individually (Va. Ct. App. 2025). · cites it 6× “Paul’s claims under Code § 18.2-457 Paul claims that the September 5, October 27, and January 29 contempt orders violated Code § 18.”
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