Convictions over sexual gesture reversed

RICHMOND, Va. — The Virginia Court of Appeals overturned two convictions for obscene sexual display. “To constitute an ‘explicitly simulated’ act of masturbation, the conduct must, as perceived by a reasonable observer, unambiguously imitate the physical act of masturbation,” and the conduct in this case, “a brief, clothed grab-and-shake directed at a known adversary in a context of longstanding hostile confrontation,” did not qualify.