Butcher v. Commonwealth (P)

The court affirmed the appellant’s conviction for failure to stop at the scene of an accident. The sole question on appeal was whether he complied with the statutory requirement to “report his name, address, driver’s license number, and vehicle registration number forthwith” to an appropriate person.

To meet the statutory command of Code § 46.2-894, the appellant only needed to report “forthwith” the required information to one person described in the statutory list. Evidence sufficiently established that he didn’t report the required information to the driver of the car he ran off the road, and no evidence suggested that he was trying to do so. The fact that the other driver knew his name and address doesn’t excuse his failure to provide his driver’s license number or vehicle registration number, as required by the statute.

Absent a circumstance that makes an immediate report impossible or wholly impractical, the statutory command that the report be made “forthwith” requires an immediate report. No such circumstance is present here.


Butcher v. Commonwealth (P), No. 0974-16-2, Nov. 6, 2018. CAV (Russell) from Petersburg (Teefey).

Categories: Court of Appeals of Virginia, Opinions, Published

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