Any person who (i) with fraudulent intent alters any certificate of title, salvage/nonrepairable certificate, or registration card issued by the Department or by any other state, (ii) with fraudulent intent, makes a false statement on any application for a certificate of title, salvage/nonrepairable certificate, or registration card issued by the Department or any other state, (iii) forges or counterfeits any certificate of title, salvage/nonrepairable certificate, or registration card purporting to have been issued by the Department under the provisions of this title or by any other state under a similar law or laws or, with fraudulent intent, alters or falsifies, or forges any assignment of title, or salvage/nonrepairable certificate, (iv) holds or uses any certificate, registration card, or assignment, knowing the same to have been altered, forged, or falsified, shall be guilty of a Class 6 felony.
It shall be unlawful for any person to conspire with any other person to violate the provisions of this section.
Code 1950, § 46-12; 1958, c. 541, § 46.1-85; 1986, c. 490; 1989, c. 727; 1996, cc. 591, 917.
Notes of Decisions
Cited in
8
cases (
2 in the last 5 years), 1993–2026 · leading case:
Smith v. Commonwealth, 434 S.E.2d 914 (Va. Ct. App. 1993).
Smith v. Commonwealth, 434 S.E.2d 914 (Va. Ct. App. 1993).
· cites it 26× “On appeal from his conviction of violating Code § 46.2-605, Charles K. Smith, Jr., contends that the trial court erred in refusing an instruction permitting the jury to find him guilty of a traffic infraction under Code § 46.”
Dalton v. Commonwealth, 499 S.E.2d 22 (Va. Ct. App. 1998).
· cites it 20× “In a request similar to appellant's, Smith tendered an instruction that would have permitted the jury to find him guilty of violating Code § 46.”
Swanson v. Commonwealth, 692 S.E.2d 256 (Va. Ct. App. 2010).
· cites it 2× “The trial court convicted Stephen James Swanson (appellant) of forging a certificate of title, in violation of Code § 46.2-605; uttering a forged certificate of title, in violation of Code § 18.”
Ronald Dean Northcraft v. Commonwealth of Virginia, 892 S.E.2d 351 (Va. Ct. App. 2023).
· cites it 12× “2(A), five counts of making a false statement on an application for a certificate of title, in violation of Code § 46.2-605, one count of money laundering, in violation of Code § 18.”
Frank Dwain Vaught v. Commonwealth of Virginia, No. 2090083 (Va. Ct. App. Nov. 10, 2009).
· cites it 12× “Frank Dwain Vaught (appellant) was convicted by the trial court of fraudulently altering, falsifying, or forging a certificate of title, in violation of Code § 46.2-605. Appellant argues on appeal that the evidence was insufficient to find that he had the requisite intent to…”
Steven Gordon Keene v. Commonwealth, No. 2200022 (Va. Ct. App. Oct. 21, 2003).
· cites it 2× “The trial court convicted Steven Gordon Keene of three counts of making a false statement on an application for an automobile certificate of title, Code § 46.2-605. He maintains he was not tried within nine months of the finding of probable cause, Code § 19.”
Matthew Raymond Shropshire v. Commonwealth of Virginia, No. 0536143 (Va. Ct. App. Mar. 24, 2015).
· cites it 2× “2-178, and one count of obtaining DMV documents by fraud, in violation of Code § 46.2-605. On May 21, 2013, appellant entered a plea of no contest on the false pretenses charge.”
Northcraft, No. 3:25-cv-00853 (E.D. Va. May 4, 2026).
“2(A), five counts of making a false statement on an application for a certificate of title, in violation of Code § 46.2-605, one count of money laundering, in violation of Code § 18.”
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