Va. Code » Title 19.2. Criminal Procedure » Chapter 15. Trial and Its Incidents » Article 4. Trial by Jury
Virginia Code

Va. Code Ann. § 19.2-264.1 (2026)

Views by juries

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The jury in any criminal case may, at the request of either the attorney for the Commonwealth or any defendant, be taken to view the premises or place in question, or any property, matter or thing relating to the case, when it shall appear to the court that such view is necessary to a just decision.

Code 1950, § 8-216; 1977, c. 624.

Notes of Decisions
Cited in 8 cases (1 in the last 5 years), 1991–2023 · leading case: Quesinberry v. Commonwealth, 402 S.E.2d 218 (Va. 1991).
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Quesinberry v. Commonwealth, 402 S.E.2d 218 (Va. 1991). · cites it 2× “” Code § 19.2-264.1. Whether such request should be granted lies within the discretion of the trial court.”
Smith v. Commonwealth, 633 S.E.2d 188 (Va. Ct. App. 2006). · cites it 2× “Code § 19.2-264.1 provides that a jury “in any criminal case may, at the request of the attorney for the Commonwealth or any defendant, be taken to view the premises or place in question, or any property, matter or thing relating to the case, when it shall appear to the Court…”
Henshaw v. Commonwealth, 451 S.E.2d 415 (Va. Ct. App. 1994). · cites it 2× “See Code § 19.2-264.1 (codifying trial court’s *347 discretion in allowing a view during trial); see also Litton v.”
Tross v. Commonwealth, 464 S.E.2d 523 (Va. Ct. App. 1995). · cites it 2× “Here there are many factors that are important in determination of the case, the lighting, the time of day, how the lights were reflecting, various things.”
Prieto v. Commonwealth, 283 Va. 149 (2012). · cites it 3× “The circumstances of Red Onion were, therefore, irrelevant and would not have been an aid to the jury in their evaluation of Prieto's future dangerousness.”
John Robert Martin v. Commonwealth of Virginia, No. 0757223 (Va. Ct. App. Apr. 18, 2023). · cites it 2× “Code § 19.2-264.1 states: The jury in any criminal case may, at the request of either the attorney for the Commonwealth or any defendant, be taken to view the premises or place in question, or any property, matter or thing relating to the case, when it shall appear to the court…”
Charles Walter Clay, Jr. v. Commonwealth of VA, No. 0619992 (Va. Ct. App. Sept. 5, 2000). · cites it 2× “2d 388, 389-90 (1980) (holding under Code § 19.2-264.1, which provides that accused may not be convicted for driving while intoxicated and reckless driving "growing out of the same act or acts," that the difference in venue does not "alter[] the singular nature of the act or…”
Scottie Tyrone Booker v. Commonwealth, No. 0061962 (Va. Ct. App. Mar. 18, 1997). · cites it 2× “" Appellant argues that the trial court erred when it granted -3- the Commonwealth's motion for a jury view of the crime scene.”
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