Va. Code » Title 64.2. Wills, Trusts, and Fiduciaries » Subtitle IV. Fiduciaries and Guardians » Part A. Fiduciaries » Chapter 12. Commissioners of Accounts
Virginia Code

Va. Code Ann. § 64.2-1212 (2026)

Exceptions to report; examination, correction, and confirmation

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A. If no exceptions have been filed, the report shall stand confirmed on the day next following the expiration of the period of 15 days after the day on which the report was filed in the clerk's office.

B. If exceptions have been filed, the circuit court, after 15 days from the time the report has been filed in its office, shall examine such exceptions that have been timely filed. The court shall correct any errors that appear on the exceptions and to this end may (i) commit the report to the same or another commissioner of accounts, as often as it sees cause, (ii) cause a jury to be empaneled to inquire into any matter that in its opinion should be ascertained in that way, or (iii) confirm the report in whole or in a qualified manner. The court shall certify in the order that it has made a personal examination of the exceptions.

Code 1919, § 5428; 1922, p. 873; 1928, p. 23; 1940, p. 614; 1944, p. 107; Code 1950, § 26-33; 1966, c. 335; 2012, c. 614.

Notes of Decisions
Cited in 4 cases (2 in the last 5 years), 2017–2023 · leading case: Gray v. Binder, 805 S.E.2d 768 (Va. 2017).
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Gray v. Binder, 805 S.E.2d 768 (Va. 2017). · cites it 4× “Code § 64.2-1212. Given these provisions, Gray’s contention that circuit courts have equitable jurisdiction, while commissioners have limited probate jurisdiction is misplaced.”
Henderson v. Cook, 831 S.E.2d 717 (Va. 2019). · cites it 10× “" Code § 64.2-1212(B). The plain language of Code § 64.”
Phillips v. Rohrbaugh, 300 Va. 289 (2021). · cites it 2× “See Code § 64.2-1212(B). In addition, Code § 64.”
Kishna Shirese Minor v. Anne M. Heishman Comm'r of Accounts, 892 S.E.2d 667 (Va. Ct. App. 2023). · cites it 3× “Code § 64.2-1212. However, the Commissioner bears no duty to prove the facts, opinions, and legal conclusions contained in her report.”
Va. Code Ann. § 64.2-1212(B): 2 cases
Henderson v. Cook, 831 S.E.2d 717 (Va. 2019). “" Code § 64.2-1212(B). The plain language of Code § 64.”
Phillips v. Rohrbaugh, 300 Va. 289 (2021). “See Code § 64.2-1212(B). In addition, Code § 64.”
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