Virginia Code
Va. Code Ann. § 8.01-426 (2026)
"Judgment" includes decree
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A decree for land or specific personal property, and a decree or order requiring the payment of money, shall have the effect of a judgment for such land, property, or money, and be embraced by the word "judgment," where used in this chapter or in Chapters 18, 19 or 20 of this title or in Title 43; but a party may proceed to carry into execution a decree or order other than for the payment of money, as he might have done if this and the following section had not been enacted.
Code 1950, § 8-343; 1977, c. 617; 2005, c. 681.
Notes of Decisions
Cited in 18
cases, 1987–2018 · leading case: Brown v. Brown, 361 S.E.2d 364 (Va. Ct. App. 1987).
Brown v. Brown, 361 S.E.2d 364 (Va. Ct. App. 1987). “3 is governed by Code § 8.01-426. Under that statute: A decree .”
Arthur G. Kahn v. Eileen McNicholas, 795 S.E.2d 485 (Va. Ct. App. 2017). “Code § 8.01-426 states, in pertinent part: "A decree .”
Adcock v. Com., Dept. of Soc. Servs., 719 S.E.2d 304 (Va. 2011). “In Bennett , the Court of Appeals stated that a support order or decree requiring the payment of money was a judgment pursuant to Code § 8.01-426, but, regarding whether such a judgment was subject to a statute of limitations, the court noted a distinction between support orders…”
Bennett v. Commonwealth, 422 S.E.2d 458 (Va. Ct. App. 1992). “Code § 8.01-426 embraces the terms “decree or order requiring the payment of money” within the definition of “judgment” and, thus, provides the statutory justification for the interchangeable use of these terms by legal writers in the factual context of most cases.”
Booth v. Booth, 371 S.E.2d 569 (Va. Ct. App. 1988). “3(D) provides: “An award entered pursuant to this subsection shall constitute a judgement within the meaning of Code § 8.01-426 and the provisions of § 8.”
Owens v. Owens, 589 S.E.2d 488 (Va. Ct. App. 2003). “In this case, we see no basis for concluding that the four-month period provided by the trial court in its final decree constitutes an abuse of discretion.”
Johnson v. Johnson, 694 S.E.2d 797 (Va. Ct. App. 2010). “An award entered pursuant to this subsection shall constitute a judgment within the meaning of [Code] § 8.01-426 and shall not be docketed by the clerk unless the decree so directs.”
Faysal M. Zedan v. Sylvie E. Westheim, 741 S.E.2d 792 (Va. Ct. App. 2013). “” Code § 8.01-426. “The entry of an order or decree of support for a spouse or for support and maintenance of a child under the provisions of this chapter of §§ 20-107.”
Adcock v. Com., Dept. of Soc. Servs., 693 S.E.2d 757 (Va. Ct. App. 2010). “It is in that sense an order requiring the payment of money and is a judgment embraced within the provisions of Code § 8.01-426." Bennett, 15 Va.App. at 141 , 422 S.”
Hayden v. Hayden, 20 Va. Cir. 255 (Wise Norton Cir. Ct. 1990). “3, saying (per § 8.01-426): a spousal support award is "essentially different from an ordinary debt or judgment for money.”
Babette C. Whitney v. Christopher J.R. Whitney, No. 2192062 (Va. Ct. App. May 15, 2007). “3(D), which provides that monetary awards “shall constitute a judgment,” implies attorney fee awards entered in divorce proceedings are not judgments.”
Nicholas P. Mihnovets v. Sharon Arnold Mihnovets, No. 2087034 (Va. Ct. App. Aug. 31, 2004). “Furthermore, under Code § 8.01-426, the final decree is a judgment against husband.”
Va. Code Ann. § 8.01-426(C): 1 case
Chowdhury v. OmniGuru Sys., Inc., 71 Va. Cir. 306 (Fairfax Cir. Ct. 2006).
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