Va. Code » Title 18.2. Crimes and Offenses Generally » Chapter 4. Crimes Against the Person » Article 4. Assaults and Bodily Woundings
Virginia Code

Va. Code Ann. § 18.2-57.1 (2026)

Repealed

✓ current as of May 2026
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Repealed by Acts 1997, c. 833.

Notes of Decisions
Cited in 14 cases (3 in the last 5 years), 1987–2023 · leading case: Henry v. Commonwealth, 462 S.E.2d 578 (Va. Ct. App. 1995).
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Henry v. Commonwealth, 462 S.E.2d 578 (Va. Ct. App. 1995). · cites it 20× “Henry argues that the evidence was insufficient to convict him of escape, and that his misdemeanor convictions in general district court bar on double jeopardy grounds his circuit court conviction under Code § 18.”
Wynn v. Commonwealth, 362 S.E.2d 193 (Va. Ct. App. 1987). · cites it 6× “He claims that, at most, he was guilty of the lesser included offense of assault in violation of Code § 18.2-57.1. The trial court refused to admit evidence of Wynn’s intent and to instruct the jury on assault.”
South v. Commonwealth, 623 S.E.2d 419 (Va. Ct. App. 2005). · cites it 8× “2-57(E) (formerly codified at Code § 18.2-57.1). This omission has continued despite the many amendments to Code § 18.”
Goodwin v. Hare, 436 S.E.2d 605 (Va. 1993). · cites it 4× “[3] In fact, Code § 18.2-57.1 expressly penalizes assault and battery upon law-enforcement officials.”
Daniel Stith v. Commonwealth of Virginia (Va. Ct. App. 2001). · cites it 10× “2-57, the sentencing order incorrectly cites Code § 18.2-57.1. Prior to 1997, Code § 18.”
Carlun Fontaine Hart v. Commonwealth of Virginia (Va. Ct. App. 2016). · cites it 2× “Carlun Fontaine Hart (“appellant”) was convicted in a bench trial of misdemeanor assault and battery in violation of Code § 18.2-57.1 The circuit court sentenced appellant to twelve months in jail, and then suspended all twelve months of his sentence.”
Carlun Fontaine Hart v. Commonwealth of Virginia (Va. Ct. App. 2017). · cites it 2× “Carlun Fontaine Hart (“appellant”) was convicted in a bench trial of misdemeanor assault and battery in violation of Code § 18.2-57.1 The circuit court sentenced appellant to twelve months in jail, and then suspended all twelve months of his sentence.”
Carlun Fontaine Hart v. Commonwealth of Virginia (Va. Ct. App. 2017). · cites it 2× “Carlun Fontaine Hart (“appellant”) was convicted in a bench trial of misdemeanor assault and battery in violation of Code § 18.2-57.1 The circuit court sentenced appellant to twelve months in jail, and then suspended all twelve months of his sentence.”
Thomas Bartholomew Simpson v. Commonwealth of Virginia (Va. Ct. App. 2017). · cites it 2× “2, and assault and battery, in violation of Code § 18.2-57.1 On appeal, he argues that the trial court erred when it admitted certain evidence—specifically, portions of a recorded 911 call containing a child’s statement audible in the background and screenshot images of text…”
Anthony Brian Barnett v. Commonwealth of Virginia (Va. Ct. App. 2021). · cites it 2× “2-41, and assault and battery, in violation of Code § 18.2-57.1 The court denied appellant’s motions to strike the evidence and to set aside the verdicts.”
Cody Alexander Lowe v. Commonwealth of Virginia (Va. Ct. App. 2023). · cites it 2× “Lowe pled to a deferred disposition and stipulated to facts sufficient to convict him under Code § 18.2-57.1 The JDR court found that the facts were sufficient for a finding of guilt and deferred adjudication until June 1, 2023.”
Salodus Zeloter Hicks IV, s/k/a Salodius Z. Hicks v. Commonwealth of Virginia (Va. Ct. App. 2023). · cites it 2× “5:3, and assault and battery, in violation of Code § 18.2-57.1 Appellant contends the court erred by failing to strike a juror for cause.”
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