Mitchell v. Commonwealth
In Mitchell v. Commonwealth, 26 Va. App. 27, 492 S.E.2d 839 (1997), the Court ruled that roads within a mobile home complex were "highways."
The roads in the complex, while private, were open for public use.
The Court found "no evidence in this record proved that the streets . . . were 'restricted exclusively to the private use of the mobile home dwellers or those persons who visited them.'" Id. at 34, 492 S.E.2d at 842.