Virginia Code

Va. Code Ann. § 8.01-21 (2026)

Judgment when death or disability occurs after verdict but before judgment

✓ current as of May 2026

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When a party dies, or becomes convicted of a felony or insane, or the powers of a party who is a personal representative or committee cease, if such fact occurs after verdict, judgment may be entered as if it had not occurred.

Code 1950, § 8-145; 1977, c. 617.

Notes of Decisions

Cited in 5 cases, 1986–2009 · leading case: Bulala v. Boyd, 389 S.E.2d 670 (Va. 1990).

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Bulala v. Boyd, 389 S.E.2d 670 (Va. 1990). · cites it 22× “What is the effect, under Va.Code Ann. §§ 8.01-21, 8.01-25, and 8.01-56, of Veronica Boyd's death after verdict but before judgment in this case? II FACTS The facts, which are substantially undisputed, are set forth in the opinion of the federal court, Boyd v.”

Centra Health, Inc. v. Mullins, 670 S.E.2d 708 (Va. 2009). · cites it 6× “Upon referral of certified questions of law from the United States Court of Appeals, we addressed, inter alia, the issue of the effect, under Code §§ 8.01-21, 8.01-25, and 8.01-56, of the child's death on the district court's ability to enter a final judgment.”

Boyd v. Bulala, 647 F. Supp. 781 (W.D. Va. 1986). · cites it 5× “Such an interpretation would create a conflict between those sections and § 8.01-21, which provides as follows: When a party dies, or becomes convicted of a felony or insane, or the powers of a party who is a personal representative or committee cease, if such fact occurs after…”

Boyd v. Bulala, 672 F. Supp. 915 (W.D. Va. 1987). · cites it 2× “Moreover, Virginia Code § 8.01-21 specifically provides for the entry of judgment when a party dies after the verdict.”

Boyd v. Bulala, 877 F.2d 1191 (4th Cir. 1989). · cites it 3× “Specifically, did the district court correctly enter judgment on these verdicts pursuant to Va. Code Ann. § 8.01-21 (1984) or should Veronica’s suit have been converted to a wrongful death action pursuant to Va.”

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