Graham v. Commonwealth (1994)
In Graham v. Commonwealth, 18 Va. App. 303, 443 S.E.2d 586, 587, 10 Va. Law Rep. 1338 (Va. 1994), the court held that even a criminal conviction was not void on account of the fact that no guardian ad litem was appointed to defend the interests of the minor defendant, but only that the conviction was voidable.
It further held that such a voidable judgment could not be set aside in a collateral proceeding. Id.
Thus, only a direct challenge, and not a collateral attack, can annul a judgment for the failure to appoint a guardian ad litem.