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Virginia Code

Va. Code Ann. § 8.01-45 (2026)

Action for insulting words

✓ current as of May 2026
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All words shall be actionable which from their usual construction and common acceptance are construed as insults and tend to violence and breach of the peace.

Code 1950, § 8-630; 1977, c. 617.

Notes of Decisions
Cited in 59 cases (5 in the last 5 years), 1980–2025 · leading case: Crawford v. United Steelworkers, Afl-cio, 335 S.E.2d 828 (Va. 1985).
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Crawford v. United Steelworkers, Afl-cio, 335 S.E.2d 828 (Va. 1985). · cites it 58× “Plaintiffs contended, in summary, as follows: that the suit arose under Code § 8.01-45 (generally referred to as the insulting words statute), as well as under the common law of Virginia; that the Local acted as agent for the International in all events complained of, thereby…”
Jarrett v. Goldman, 67 Va. Cir. 361 (Portsmouth Cir. Ct. 2005). · cites it 23× “Jarrett claims that the statements of Goldman and Webb, referenced above from ¶¶ 7 and 8 (“you are a stupid motherfucker” and “you are a fucking idiot”), “from their usual construction and common ' acceptance, are insulting and tending to provoke violence and breach of the…”
Steele v. Goodman, 382 F. Supp. 3d 403 (E.D. Va. 2019). · cites it 7× “" Va. Code Ann. § 8.01-45 . This section provides, in relevant part: Any two or more persons who combine, associate, agree, mutually undertake or concert together for the purpose of.”
Gazette, Inc. v. Harris, 325 S.E.2d 713 (Va. 1985). · cites it 4× “I concur in the action of the majority in reversing the punitive-damage award in the Port Packet case.”
Hutchins v. Cecil, 44 Va. Cir. 380 (Fairfax Cir. Ct. 1998). · cites it 52× “Hutchins claims that a cause of action under Va. Code § 8.01-45 is completely assimilated into common law libel or slander.”
Martin v. Lagualt, 315 F. Supp. 2d 811 (E.D. Va. 2004). · cites it 9× “The remainder of the motion for judgment attempts to set forth claims for common law defamation and under Virginia Code § 8.01-45. Defendants were served with a copy of the motion for judgment on March 8, 2004.”
Yeagle v. Collegiate Times, 497 S.E.2d 136 (Va. 1998). · cites it 4× “Yeagle filed a motion for judgment against the Collegiate Times, alleging that the phrase "Director of Butt Licking" constituted common law defamation, defamation per se, and use of insulting words under Code § 8.01-45. The trial court sustained the Collegiate Times' demurrer on…”
Allen & Rocks, Inc. v. Dowell, 477 S.E.2d 741 (Va. 1996). · cites it 10× “The dispositive issue in this appeal is whether an action under the insulting words statute, Code § 8.01-45, 1 may be maintained absent proof that the insulting words were such as to “tend to violence and breach of the peace.”
Goulmamine v. CVS Pharmacy, Inc., 138 F. Supp. 3d 652 (E.D. Va. 2015). · cites it 4× “” Va.Code § 8.01-45. The parties disagree over three main legal issues: whether CVS uttered insults which tend to violence and breach of the peace, whether Goulmamine was required to state verbatim the insulting words giving rise to an insulting words claim, and whether CVS may…”
Trail v. Gen. Dynamics Armament & Technical Prods., Inc., 697 F. Supp. 2d 654 (W.D. Va. 2010). · cites it 8× “” Va.Code Ann. § 8.01-45. Virginia’s insulting words statute has been interpreted as being “ ‘co-extensive with the common law action for defamation.”
Levine v. McLeskey, 881 F. Supp. 1030 (E.D. Va. 1995). · cites it 3× “Although Virginia has a defamation statute, Va.Code § 8.01-45, which states that "[a]ll words shall be actionable which from their usual construction and common acceptance are construed as insults and tend to violence and breach of the peace,” plaintiffs do not sue under this…”
Telco Commc'ns v. an Apple a Day, 977 F. Supp. 404 (E.D. Va. 1997). · cites it 2× “Specifically, TELCO alleges five counts: (1) Defamation under Section 8.01-45 of the Virginia Code; (2) Common Law Defamation; (3) Tortious Interference with a Contractual Relationship and Reasonable Business Expectation; (4) Conspiracy to Harm Business in violation of Sections…”
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