O'Banion v. Commonwealth

In O'Banion v. Commonwealth, 33 Va. App. 47, 531 S.E.2d 599 (2000), after the police arrested O'Banion for trespassing, they found a steak knife and a box-cutter on his person. Id. at 54, 531 S.E.2d at 602-03. In finding both of these items were "weapons" under Code 18.2-308, the Court noted, "by its terms, the Code prohibits the carrying of a concealed razor or any weapon of like kind." Id. at 59, 531 S.E.2d at 605. The Court continued, explaining that a box-cutter, by incorporating a razor, fit within the definition of "razor" as a "weapon" that cannot be concealed under the statute. Id. at 60, 531 S.E.2d at 605. The Court did not define "razor" as a box-cutter but instead found a box-cutter was an example of a razor. See id. O'Banion essentially held that the statute did not simply proscribe a razor blade, but was expansive enough to include an object that incorporated a razor.