Muhammad v. Commonwealth

“Forgery is a common law crime in Virginia.” Fitzgerald v. Commonwealth, 227 Va. 171, 173, 313 S.E.2d 394, 395 (1984). “[It] is the false making or materially altering with intent to defraud, of any writing which, if genuine, might apparently be of legal efficacy, or the foundation of legal liability.” Bullock v. Commonwealth, 205 Va. 558, 561, 138 S.E.2d 261, 263 (1964). A century ago, the Supreme Court explained:

The instrument must appear on its face to be, or be in fact, one which, if true, would be valid or legally capable of effecting a fraud. Writings invalid on their face are not…