Va. Code » Title 19.2. Criminal Procedure » Chapter 16. Evidence and Witnesses » Article 2. Witnesses from or for Another State
Virginia Code

Va. Code Ann. § 19.2-272 (2026)

Definitions

✓ current as of May 2026
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"Witness" as used in this article shall include a person whose testimony is desired in any proceeding or investigation by a grand jury or in a criminal action, prosecution or proceeding.

The word "state" shall include any territory of the United States and the District of Columbia.

The word "summons" shall include a subpoena (both subpoena ad testificandum and subpoena duces tecum), order or other notice requiring the appearance of a witness or production of documents.

Code 1950, § 19.1-269; 1960, c. 366; 1975, c. 495; 1988, c. 34.

Notes of Decisions
Cited in 10 cases (3 in the last 5 years), 1979–2026 · leading case: Coleman v. Commonwealth.
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Coleman v. Commonwealth (Va. 1983). · cites it 2× “2 The record shows that the trial court, upon affidavit of the Commonwealth Attorney, entered an order on March 11, 1982, under The Uniform Act to Secure the Attendance of Witnesses from without a State in Criminal Proceedings, Code § 19.2-272, et seq., to secure the attendance…”
Gray v. Commonwealth (Va. Ct. App. 1993). · cites it 4× “The record shows that, in the week before the trial, subpoenas were served on the witnesses in New York pursuant to the Uniform Act to Secure the Attendance of Witnesses from without a State in Criminal Proceedings, Code §§ 19.2-272 through 19.2-282 (hereinafter the Uniform Act).”
Arkansas Chronicle v. Easley (E.D. Va. 2004). · cites it 3× “See Va.Code § 19.2-272 et seq.; 22 Okla. St. § 721 et seq.”
Ormound v. Sheriff, Clark Cnty. (Nev. 1979). “See Va. Code §§ 19.2-272 to -282. We express no opinion on what efforts must be made to secure the attendance of a witness who resides in a state that has not adopted the Act.”
State v. Dowling (Me. 1982). “…The State of Virginia, where the records, and presumably their custodian, were located, has adopted the same Act. Va.Code 1950 §§ 19.2-272 to 19.2-282.”
Tobias Ogbanna Reed v. Commonwealth of Virginia (Va. Ct. App. 2016). · cites it 2× “Appellant argues that the Commonwealth must have issued and served the subpoena duces tecum pursuant to the Uniform Act to Secure the Attendance of Witnesses from without a State in Criminal Proceedings, Code §§ 19.2-272 through 19.2-282. However, Verizon’s voluntary acceptance…”
Nathan Elmore Thomas v. Commonwealth of Virginia (Va. Ct. App. 2024). · cites it 2× “None of those subpoenas were issued in accordance with the governing Code § 19.2-272 et seq. On January 13, 2023, the United States removed the subpoenas to the United States District Court for the Eastern District of Virginia and moved to quash them.”
Heather Ford, Sometimes Known as Heather D'Anne Ford v. Commonwealth of Virginia (Va. Ct. App. 2025). “” Code § 19.2-272. In the context of defining the rights of witnesses, among those rights are various forms of “Courtroom assistance,” including “a separate waiting area during court proceedings.”
Hilary Baltimore Edmond v. Commonwealth of Virginia (Va. Ct. App. 2026). “2-391(H) makes it a violation of Code § 19.2-272 for “[a]ny person who operates a motor vehicle” while his license is revoked and -5- “where the provisions of subsection D do not apply.”
Corwyn Cordell Skinner v. Commonwealth (Va. Ct. App. 1997). · cites it 2× “2d at 90 (holding that defendant exercised due diligence when he timely and properly subpoenaed out-of-state witnesses under Uniform Act to Secure the Attendance of Witnesses from without a State in Criminal Proceedings, pursuant to Code §§ 19.2-272 through 19.2-282). Because…”
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