Va. Code » Title 19.2. Criminal Procedure » Chapter 14. Presentments, Indictments and Informations » Article 2. Form and Requisites
Virginia Code

Va. Code Ann. § 19.2-230 (2026)

Bill of particulars

✓ current as of May 2026
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A court of record may direct the filing of a bill of particulars at any time before trial. A motion for a bill of particulars shall be made before a plea is entered and at least seven days before the day fixed for trial and the bill of particulars shall be filed within such time as is fixed by the court.

1975, c. 495.

Notes of Decisions
Cited in 32 cases (6 in the last 5 years), 1991–2026 · leading case: Joaquin Shadow Rams, Sr., a/k/a, etc. v. Commonwealth of Virginia, 823 S.E.2d 510 (Va. Ct. App. 2019).
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Joaquin Shadow Rams, Sr., a/k/a, etc. v. Commonwealth of Virginia, 823 S.E.2d 510 (Va. Ct. App. 2019). · cites it 2× “Pursuant to Code § 19.2-230, a court of record “may direct the filing of a bill of particulars.”
Yeager v. Commonwealth, 433 S.E.2d 248 (Va. Ct. App. 1993). · cites it 12× “On May 2, 1991, appellant requested a bill of particulars pursuant to Code § 19.2-230 seeking the precise facts and circumstances constituting the offenses under all three indictments.”
Bruhn v. Commonwealth, 559 S.E.2d 880 (Va. Ct. App. 2002). · cites it 12× “The Commonwealth's position also fails to consider that, in 1975 when the legislature adopted Code § 19.2-230 granting all criminal defendants the right to a bill of particulars, it did not eliminate the provision in Code § 18.”
Commonwealth v. Bruhn, 570 S.E.2d 866 (Va. 2002). · cites it 4× “The dissent concluded that the availability of a bill of particulars as the result of the 1975 enactment of Code § 19.2-230 had rendered this provision unnecessary, and that the continued association of embezzlement with larceny within the overall scheme of property crimes…”
Muhammad v. Com., 619 S.E.2d 16 (Va. 2005). · cites it 2× “E.2d at 123 n. 1. We held that the indictment in Goins was sufficient.”
Weeks v. Angelone, 4 F. Supp. 2d 497 (E.D. Va. 1998). · cites it 8× “Petitioner maintains that the Virginia eases cited by this court 1 only apply to requests made under Va.Code § 19.2-230, which has discretionary language, and not § 19.”
Remington v. Commonwealth, 551 S.E.2d 620 (Va. 2001). · cites it 2× “(iv) Whether the circuit “court’s denial of [Remington’s] motion for a bill of particulars violated] Remington’s rights under the Virginia and federal constitutions as well as [Code § 19.2-230].” See Walker v. Commonwealth, 258 Va.”
Goins v. Commonwealth, 470 S.E.2d 114 (Va. 1996). · cites it 2× “Code § 19.2-230 provides that a trial court “may direct the filing of a bill of particulars.”
Lewis v. Commonwealth, 813 S.E.2d 732 (Va. 2018). · cites it 2× “Code § 19.2-230 ; see also Pine v. Commonwealth , 121 Va.”
Sims v. Commonwealth, 507 S.E.2d 648 (Va. Ct. App. 1998). · cites it 4× “Appellant moved the court for a bill of particulars pursuant to Code §§ 19.2-230 and 19.2-266.2 and the Due Process Clauses of the United States and Virginia Constitutions.”
Joseph Louis Paduano v. Commonwealth of Virginia, 766 S.E.2d 745 (Va. Ct. App. 2014). · cites it 4× “2-63____ Prior to trial on these indictments, appellant filed a motion for a bill of particulars pursuant to Code §§ 19.2-230 and 19.2-266.2, in which he alleged that “[appellant] has been indicted on three offenses which appear to involve the same act and/or code section.”
Roach v. Commonwealth, 468 S.E.2d 98 (Va. 1996). · cites it 2× “Roach argues that the trial court’s denial of the remaining parts of the motion constitutes error based on the gravity of the penalty sought.”
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