Background
On November 5, 2023, Blake Hughes, a restaurant employee, activated red and blue flashing lights in his minivan while parked in a restaurant lot in Virginia Beach. When coworker Abby Laurendeau left work and began driving, Hughes followed her, activating the lights immediately. Believing she was being pulled over by police, Laurendeau stopped at a nearby stop sign. Hughes exited his vehicle, approached her window laughing, and said “I’m sorry. I’m sorry. I just wanted to see if it would work.” He then hugged her without consent while she sat frozen in fear. When questioned by police the next day, Hughes initially denied exiting his vehicle. He claimed he had purchased the lights to test them and was “messing with” them to see how they functioned.
Hughes was charged with impersonating a police officer, abduction, and assault and battery. At trial, the court rejected his testimony as inconsistent with security footage showing his vehicle parked in the lot for nearly an hour before Laurendeau departed, and his prior felony convictions affected his credibility. The trial court found Hughes specifically intended to see if he could “pull someone over” using the fake lights and convicted him on all three counts, sentencing him to two years and seven months active incarceration plus five years supervised probation.
The Court’s Holding
The Court of Appeals affirmed all convictions, including Hughes’s conviction for impersonating a police officer—a first-impression case involving Virginia Code § 18.2-174’s “privileges clause.” The court held that Hughes violated this provision by activating red and blue flashing lights without legal authority. Under Code §§ 46.2-1020 and 46.2-1022, only law enforcement vehicles (and certain other entities) may display such lights. When Hughes activated these lights, he exercised a privilege “created and conferred by law” to police officers while having no authority to do so, making him a “mere usurper” into the law enforcement office. The court found both the criminal act and intent were satisfied: Hughes used the lights to initiate a traffic stop and explicitly stated his goal was to “see if it would work,” demonstrating intent to deceive.
On the abduction charge, the court held that Hughes’s deception deprived Laurendeau of her personal liberty. A reasonable motorist seeing flashing red and blue lights has no practical choice but to stop, creating a restriction on freedom of movement. Hughes’s intent to deprive her liberty could be inferred from the natural and probable consequences of impersonating a police officer. The unwanted hug constituted the required physical contact for assault and battery. The court emphasized that Hughes’s false statement to police that he never exited his vehicle—contradicted by surveillance footage—further demonstrated consciousness of guilt.
Key Takeaways
- Activating unauthorized police lights violates the “privileges clause” of Virginia’s police impersonation statute, even without wearing a uniform or verbally claiming to be an officer.
- Intent to deceive can be inferred from a defendant’s own admissions (wanting to “see if it would work”) and from the natural consequences of using police equipment that reasonably compels compliance.
- A fake traffic stop induced by flashing lights constitutes abduction when the victim is deceived into stopping and restricted in her freedom of movement by police authority.
- Witness credibility is properly evaluated by trial courts; appellate courts defer to findings rejecting a defendant’s testimony as inconsistent with physical evidence.
Why It Matters
This decision expands Virginia’s police impersonation statute beyond traditional cases involving uniforms, badges, or verbal claims of authority. By recognizing that unauthorized use of police equipment (flashing lights) violates the privileges clause, the court protects citizens from sophisticated deception tactics. The ruling applies abduction law to scenarios where victims are coerced into surrendering freedom through trickery, not physical force. Attorneys should note that courts will infer intent to deceive from circumstantial evidence—including admissions like Hughes’s own words, prior planning (sitting in the lot for an hour), and conduct consistent with impersonation (actually following and “stopping” the victim).
The decision also clarifies that the privileges clause requires no special appearance or verbal performance; merely wielding a privilege exclusive to law enforcement—whether lights, uniforms, or other tools—can trigger liability. This reflects a broader protective policy: police impersonation statutes “exist to protect citizens who would be harmed or deceived by those acting under the color of authority.”