Historic Virginia Crimes: The Night Prowler

In Fedele v. Commonwealth, 205 Va. 51 (1964), the defendant was convicted in the Police Court of the City of Richmond of being a “person of ill fame, to wit: a night prowler.”  She was required to be on good behavior for one year or else forfeit the $300 peace bond she was to pay per Va. Code § 19.1-20.

So who’s a “person of ill fame”?  And who’s a “night prowler”?  According to the opinion, a person of ill fame is nothing more than someone who has a bad reputation.  And a night prowler is one whose habit is to move about at night for the purpose of committing some crime, or disturbing the peace, or doing some wrongful or wicked act.   So, basically, under that statute, you could be ordered to post a substantial bond[1] for merely having a bad reputation for habitually moving about at night for the mere purpose of committing bad acts.  Or, in other words, you could be punished for having a bad reputation for habitually acting shady at night.  And, if you couldn’t post the required peace bond, you would be committed to jail.  What fun!


[1] $300 in 1964 has the same buying power as $2,220.75 in 2012 according the Bureau of Labor Statistics.

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Nicholas Solan

About Nicholas Solan

Nicholas Jon Solan is a founding partner of Solan Alzamora, PLLC in Fairfax, Virginia. He specializes in family law and criminal/traffic law, including but not limited to charges for speeding, reckless driving, improper driving, driving on a suspended license, DUI/DWI, possession of marijuana, possession of a controlled substance, assault and battery, and eluding the police. He can be reached at (703) 359-0088 or nsolan@SAlawfirm.com or www.SAlawfirm.com.