Quoting Turbro_Negro:
In VA if he is the registered owner a Bill of Sale is okay with the DMV, they'll issue you a title. BUT on if the bill of sale is from the last known registed owner. Or the owner could pay $10 and get a new title.
Key wording here is the LAST KNOWN or REGISTERED OWNER of that state.
This question is asked all the time folks. Who cares what Insurance card or even Registration slips say, only what the State has on record at the DMV. Until the name on the title is verified/shown the "seller" cannot pass that car on. Quit trying to find a loophole based on someone's internet suggestion(s). Unless you want to lose money and in extreme situations have a felony car theft tag on your record.