Va. Code » Title 19.2. Criminal Procedure » Chapter 12. Preliminary Hearing
Virginia Code

Va. Code Ann. § 19.2-185 (2026)

Testimony may be reduced to writing and subscribed

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When the judge deems it proper the testimony of the witnesses may be reduced to writing, and, if required by him, shall be signed by them respectively.

The judge of the court of record to which the case may be or has been certified may order the testimony of the witnesses at the preliminary hearing to be reduced to writing.

Code 1950, § 19.1-105; 1960, c. 366; 1968, c. 639; 1975, c. 495.

Notes of Decisions
Cited in 7 cases (1 in the last 5 years), 1982–2024 · leading case: Lebedun v. Commonwealth, 501 S.E.2d 427 (Va. Ct. App. 1998).
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Lebedun v. Commonwealth, 501 S.E.2d 427 (Va. Ct. App. 1998). · cites it 2× “Lebedun did not have a court reporter present for the scheduled preliminary hearing and offered no justification other than that the court reporter had not appeared. Lebedun could not determine when a court reporter would be available or whether one could be available that day.”
Hunter v. Commonwealth, 690 S.E.2d 792 (Va. Ct. App. 2010). · cites it 2× “We recognize that subsequent to Britt , our Supreme Court reversed a conviction and remanded the case for a new sentencing hearing on a lesser-included offense because "this disposition is consistent with Code § 19.2-185...." Waller v. Commonwealth, 278 Va.”
Lankford v. Foster, 546 F. Supp. 241 (W.D. Va. 1982). · cites it 3× “Va. Code § 19.2-185; Supreme Court Rules 3A:5(b)(l).”
Jaquantis Daeshon Yellock v. Commonwealth of Virginia, 896 S.E.2d 802 (Va. Ct. App. 2024). “The Commonwealth failed to establish that Thomas 6 In a post-Britt decision, this Court, stated: We recognize that subsequent to Britt, our Supreme Court reversed a conviction and remanded the case for a new sentencing hearing on a lesser-included offense because “this…”
Robert Henry Perkins s/k/a etc v. Commonwealth, No. 2944013 (Va. Ct. App. Nov. 12, 2002). · cites it 2× “It was not prepared by a court reporter, see Code § 19.2-185, nor authenticated in any way.”
In re Times-World Corp., 50 Va. Cir. 25 (Bedford Cir. Ct. 1999). · cites it 2× “Concerning the petitioners’ request that the transcript of the preliminary hearing in these cases be made public, I note that this preliminary hearing was transcribed in accordance with the order that I entered on behalf of the Circuit Court of Bedford County on September 30,…”
Allen Lebedun v. CW, No. 0233974 (Va. Ct. App. July 7, 1998). “Lebedun did not have a court reporter present for the scheduled preliminary hearing and offered no justification other than that the court reporter had not appeared.”
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