In Barber v. Commonwealth, 206 Va. 241, 142 S.E.2d 484 (Va. 1965), the defendant claimed he shot his wife while they were wrestling with the gun she aimed at him. 142 S.E.2d at 488. During the prosecution's cross-examination of the defendant, the prosecution used a toy gun to show the gunshot injuries could not have occurred the way the defendant claimed. 142 S.E.2d at 492. The defendant argued on appeal the trial court erred in allowing the prosecution to use a toy pistol for demonstrative purposes. Id. The appellate court, however, found there was no abuse of discretion. 142 S.E.2d at 493.