Hart v. Commonwealth
In Hart v. Commonwealth, 18 Va. App. 77 (1994), the accused was charged and convicted of indecent exposure under Code 18.2-387, which makes it a misdemeanor to "obscenely display or expose" ones "person, or the private parts thereof, in any public place." See Hart, 18 Va. App. at 78.
Ruling that the meaning of the word "private parts" was ambiguous, and consistent with well recited rules of statutory construction, we looked to other sections of our Code for guidance. See, 18 Va. App. at 79. This analysis supported the holding in Hart that the legislature intended "buttocks" to be "private parts" within the meaning of Code 18.2-387. Id.