Virginia Code

Va. Code Ann. § 18.2-94 (2026)

Possession of burglarious tools, etc

✓ current as of May 2026

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If any person have in his possession any tools, implements or outfit, with intent to commit burglary, robbery or larceny, upon conviction thereof he shall be guilty of a Class 5 felony. The possession of such burglarious tools, implements or outfit by any person other than a licensed dealer, shall be prima facie evidence of an intent to commit burglary, robbery or larceny.

Code 1950, § 18.1-87; 1960, c. 358; 1970, c. 587; 1975, cc. 14, 15.

Notes of Decisions

Cited in 56 cases (6 in the last 5 years), 1979–2026 · leading case: Edwards v. Commonwealth, 672 S.E.2d 894 (Va. Ct. App. 2009).

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Edwards v. Commonwealth, 672 S.E.2d 894 (Va. Ct. App. 2009). · cites it 184× “Shakil Edwards (Edwards) appeals her conviction for possession of a tool, implement or outfit with the intent to commit larceny, in violation of Code § 18.2-94. Edwards contends that the evidence was insufficient as a matter of law to prove that the purse she carried at the time…”

Williams v. Commonwealth, 649 S.E.2d 717 (Va. Ct. App. 2007). · cites it 132× “Kenney Quinard Williams ("Williams") appeals his conviction of possession of burglarious tools, in violation of Code § 18.2-94. He argues that (1) the trial court erred in construing the statute to include a plastic bag as a larcenous "implement," and (2) the statute is void for…”

Edwards v. Commonwealth, 661 S.E.2d 488 (Va. Ct. App. 2008). · cites it 96× “2-96, and possession of a burglarious tool in violation of Code § 18.2-94. Appellant contends the evidence was insufficient as a matter of law to convict her of violating Code § 18.”

Gheorghiu v. Commonwealth, 682 S.E.2d 50 (Va. Ct. App. 2009). · cites it 36× “3 (case numbers CR05-1241 through CR05-1243, CR05-1247, and CR05-1248); three counts of credit card fraud, in violation of Code § 18.”

Mercer v. Commonwealth, 512 S.E.2d 173 (Va. Ct. App. 1999). · cites it 24× “Jessie Lamont Mercer, also known as Tony Horice Davis, (appellant) appeals from his conviction by the Circuit Court of the City of Virginia Beach (trial court) for violating Code § 18.2-94. The sole issue, presented is whether the evidence was sufficient to find him guilty of…”

Moss v. Commonwealth, 509 S.E.2d 510 (Va. Ct. App. 1999). · cites it 16× “certain tools, specifically, stolen keys, “with intent to commit burglary, robbery or larceny,” in violation of Code § 18.2-94. On appeal, defendant challenges the sufficiency of the evidence to prove the offense.”

Hagy v. Commonwealth, 543 S.E.2d 614 (Va. Ct. App. 2001). · cites it 6× “Ralph Hagy was convicted in a bench trial of possession of burglarious tools, in violation of Code § 18.2-94. On appeal, Hagy argues the evidence is insufficient to support his conviction.”

Hassan Christopher Atkins v. Commonwealth of Virginia, 800 S.E.2d 827 (Va. Ct. App. 2017). · cites it 2× “On August 23, 2015, Deputy Michael Fiedler, with the Powhatan County Sheriff’s Office, responded 1 The appellant also was convicted of possession of burglarious tools and failure to appear, in violation of Code §§ 18.2-94 and 19.2-128, but those convictions are not subjects of…”

Gheorghiu v. Com., 701 S.E.2d 407 (Va. 2010). · cites it 2× “2-195, and one count of possession of burglarious tools in violation of Code § 18.2-94. Both Keltz and Kent testified that they did not live in Arlington County, did not know Gheorghiu, and did not give him permission to use their credit card numbers.”

Watkins v. Commonwealth, 494 S.E.2d 859 (Va. Ct. App. 1998). · cites it 2× “The possession of such burglarious tools, implements or outfit by any person other than a licensed dealer, shall be prima facie evidence of an intent to commit burglary, robbery or larceny.”

Carter v. Commonwealth, 290 S.E.2d 865 (Va. 1982). · cites it 3× “Carter, III, was convicted, following a bench trial, of the possession of tools with intent to commit larceny, in violation of Code § 18.2-94. 1 He was sentenced to five years in the penitentiary.”

Owens v. Commonwealth, 675 S.E.2d 879 (Va. Ct. App. 2009). · cites it 4× “On appeal from his conviction of possession of burglary tools, Michael Owens contends that the evidence was insufficient to support the trial court’s finding that he possessed such tools in violation of Code § 18.2-94. We affirm the judgment of the trial court.”

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