Malvo had been sentenced to life in prison without parole for the sniper-style attacks committed around the region in October 2002 along with John Allen Muhammad. Ten people were killed and three others were shot during a three-week period.
Malvo’s case has now been remanded back to Spotsylvania County Circuit Court to issue a new sentence.
Muhammad was executed in 2009 for the killings.
Muhammad and Malvo used a rifle to shoot over a dozen people from a modified trunk of a Chevrolet Caprice in random attacks in Maryland, Virginia and D.C.