Va. Code » Title 19.2. Criminal Procedure » Chapter 17. Convictions; Effect Thereof » Article 1. Proof and Verdicts
Virginia Code

Va. Code Ann. § 19.2-284 (2026)

Proof of ownership in offense relating to property

✓ laws through the 2026 session (checked Sept. 2026)
Find cases: SyfertCases citing this section VA-LISlaw.lis.virginia.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

In a prosecution for an offense committed upon, relating to or affecting real estate, or for stealing, embezzling, destroying, injuring or fraudulently receiving or concealing any personal estate it shall be sufficient to prove that when the offense was committed the actual or constructive possession, or a general or special property, in the whole or any part of such estate was in the person or entity alleged in the indictment or other accusation to be the owner thereof.

Code 1950, § 19.1-247; 1960, c. 366; 1975, c. 495.

Notes of Decisions
Cited in 5 cases, 1978–2002 · leading case: Hamm v. Commonwealth, 428 S.E.2d 517 (Va. Ct. App. 1993).
Sort: Relevance Newest Treatment
Hamm v. Commonwealth, 428 S.E.2d 517 (Va. Ct. App. 1993). · cites it 14× “ns because the Commonwealth failed to prove malice; (2) the prosecutor violated his due process rights by failing to characterize as exculpatory a laboratory report furnished to the defense in discovery; (3) the judge erred by admitting hearsay testimony of the insurance…”
Gardner v. Commonwealth, 546 S.E.2d 686 (Va. 2001). · cites it 6× “[2] Code § 19.2-284 provides as follows: In a prosecution for an offense committed upon, relating to or affecting real estate, or for stealing, embezzling, destroying, injuring or fraudulently receiving or concealing any personal estate it shall be sufficient to prove that when…”
Bruhn v. Commonwealth, 559 S.E.2d 880 (Va. Ct. App. 2002). “John Wesley Bartram, Pleading for Theft Consolidation in Virginia: Larceny, Embezzlement, False Pretenses and § 19.2-284, 56 Wash. & Lee L.Rev. 249, 275, 279 (1999) (commenting that the "notable absen[ce]" of the codification of the Pitsnogle rule in the embezzlement statute…”
Richard Wayne Nuckles v. Commonwealth, No. 2570014 (Va. Ct. App. Nov. 5, 2002). · cites it 2× “Code § 19.2-284. No indictment will be deemed invalid for the insertion of any other words or surplusage.”
Commonwealth v. Rasnake, 7 Va. Cir. 521 (Norfolk Cir. Ct. 1978). · cites it 2× “The Commonwealth responds, sufficiently, that this supposed error is cured by Code Section 19.2-284. See also Latham v. Commonwealth, 184 Va.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.