Justia Virginia Supreme Court Opinion Summaries

In June 2016, Terae Harris, driving an Enterprise rental car, backed out of a parking space and struck James Joplin on his motorcycle. Enterprise offered Joplin a $25,000 settlement in exchange for releasing all claims against both Enterprise and Harris. Joplin did not respond, and in May 2018, he sued Harris for $300,000. In May 2020, Joplin’s new attorney found the signed release and sent it to Enterprise, but it was illegible. Harris filed a plea of accord and satisfaction, claiming the release barred Joplin’s suit.The Circuit Court of Henrico County admitted an unsigned copy of the release as evidence, ruling that the parol evidence rule did not apply because the unsigned release was used to confirm the terms of the illegible signed release. The court granted Harris’ plea of accord and satisfaction, barring Joplin’s suit. Joplin appealed, arguing the unsigned release was improper parol evidence, his attorneys lacked authority to settle, and there was no mutual assent.The Court of Appeals of Virginia reversed the circuit court, holding that the unsigned release was improper parol evidence and that Harris had not met the burden of proof for its admissibility. The court did not address Joplin’s other arguments.The Supreme Court of Virginia reviewed the case and found that the circuit court did not abuse its discretion in admitting the unsigned release. The court held that the parol evidence rule did not apply because the unsigned release was used to verify the terms of the illegible signed release, not to alter them. The court also found that the circuit court’s factual finding linking the two releases was supported by a preponderance of the evidence. Consequently, the Supreme Court of Virginia reversed the Court of Appeals and entered final judgment for Harris. View "Harris v. Joplin" on Justia Law

Luka Kartozia was observed by a security guard at Turnberry Tower, a condominium high rise, acting erratically and using an outside power outlet to charge his phone. When approached by security, Kartozia claimed to know a resident, Phil Yang, but refused offers to contact him. After repeated requests to leave by security and police, Kartozia was arrested for trespassing.Kartozia was found guilty of trespassing in the Arlington County General District Court and appealed to the Arlington County Circuit Court. At the circuit court trial, Kartozia proposed a jury instruction on a good-faith claim-of-right defense, which the court denied, finding insufficient evidence to support it. The jury convicted Kartozia, and he was fined $1,000.The Court of Appeals of Virginia reversed the circuit court’s judgment, vacated the conviction, and remanded the case for retrial, ruling that the circuit court abused its discretion by not giving the proposed jury instruction. The Court of Appeals found that there was more than a scintilla of evidence supporting Kartozia’s claim that he believed he had a right to be on the property.The Supreme Court of Virginia reviewed the case and held that the circuit court did not abuse its discretion in denying the jury instruction. The court found no credible evidence that Kartozia had a reasonable, good-faith belief that he was authorized to remain on the property after being asked to leave multiple times. The Supreme Court reversed the Court of Appeals' decision and reinstated the circuit court’s judgment, affirming Kartozia’s conviction. View "Commonwealth v. Kartozia" on Justia Law

Under Wild Skies, Inc. (UWS) owned a television show called Under Wild Skies, which was sponsored by the National Rifle Association (NRA). In January 2018, UWS and the NRA entered into agreements for the production and sponsorship of the show, effective through 2025. The NRA was required to make quarterly payments. In July 2019, the NRA requested information about the show as part of an internal review. UWS initially resisted but eventually provided the information. The NRA did not respond and failed to make the September 1, 2019 payment. UWS then sued the NRA for breach of contract and anticipatory breach.The trial court rejected UWS's proposed Jury Instruction 21 on the doctrine of adequate assurance, stating it would cause the court to comment on the evidence. The jury found in favor of UWS on the breach of contract claims but in favor of the NRA on the anticipatory breach claims. UWS's motion to set aside the verdict was denied. The Court of Appeals affirmed the trial court's decision, concluding that the doctrine of adequate assurance is not recognized in Virginia law.The Supreme Court of Virginia reviewed the case and affirmed the Court of Appeals' decision. The court held that the doctrine of adequate assurance, as outlined in the Restatement (Second) of Contracts § 251, is not part of Virginia's common law. The court emphasized that the doctrine is a modern innovation and has not been adopted by Virginia appellate courts or the General Assembly, except in limited circumstances. Consequently, the trial court did not err in refusing Jury Instruction 21, as it was not an accurate statement of Virginia law. The judgment of the Court of Appeals was affirmed. View "Under Wild Skies v. NRA" on Justia Law

Jamar Paxton was arrested in May 2020 for robbery and use of a firearm following the death of his girlfriend, Dominique Danzy. During interrogation, Paxton initially denied killing Danzy but later made incriminating statements after invoking his right to remain silent. The trial court found that Paxton had unequivocally invoked his right to remain silent but denied his motion to suppress the statements, ruling that Paxton voluntarily reinitiated the interrogation. Evidence presented at trial included Paxton's purchase of a rifle, forensic evidence linking the rifle to Danzy's murder, and Paxton's possession of Danzy's car keys and a cartridge casing.The jury found Paxton guilty of second-degree murder and use of a firearm in the commission of murder, and he was sentenced to 33 years in prison with 16 years suspended. Paxton appealed to the Court of Appeals of Virginia, which ruled that the trial court erred in denying the motion to suppress his statements. The Court of Appeals held that the error was not harmless because Paxton's incriminating statements were powerful evidence in a case with circumstantial evidence. The court also ruled that Paxton did not waive his challenge by testifying.The Supreme Court of Virginia reviewed the case and determined that any error in admitting Paxton's statements was harmless beyond a reasonable doubt. The court noted that the Commonwealth downplayed the importance of Paxton's statements during closing arguments and focused on the physical evidence linking Paxton to the murder. The court concluded that the overall strength of the Commonwealth's case, including forensic evidence and Paxton's possession of Danzy's car keys, established that a rational jury would have found Paxton guilty even without the statements. The Supreme Court of Virginia reversed the decision of the Court of Appeals and affirmed Paxton's convictions. View "Commonwealth v. Paxton" on Justia Law

Norfolk Southern Railway Company challenged the constitutionality of Code § 56-16.3, which allows broadband service providers to install fiber optic cables across railroad property. The statute, enacted in 2023, aims to promote broadband expansion in Virginia. Cox Communications filed applications to install fiber optic cables under Norfolk Southern’s tracks, which Norfolk Southern did not initially oppose. However, a dispute arose over the license fees, leading Cox to proceed without a licensing agreement, prompting Norfolk Southern to seek relief from the State Corporation Commission (the “Commission”).The Commission rejected Norfolk Southern’s arguments without a hearing, finding the claims insufficient to establish undue hardship. Norfolk Southern appealed to the Supreme Court of Virginia, which stayed the Commission’s judgment during the appeal.The Supreme Court of Virginia reviewed the case de novo, focusing on whether Code § 56-16.3 violated Article I, Section 11 of the Virginia Constitution. The court emphasized that eminent domain statutes must be strictly construed and that the burden of proving public use lies with the condemnor. The court found that Code § 56-16.3 did not reference public use and allowed a private company to take property for financial gain, which is not a public use under the Virginia Constitution.The court held that the application of Code § 56-16.3 in this case constituted a taking of Norfolk Southern’s property for a nonpublic use, violating the Virginia Constitution. Consequently, the court reversed the Commission’s judgment and remanded the case for entry of judgment in favor of Norfolk Southern. View "Norfolk Southern Railway Co. v. SCC" on Justia Law

Z.M., a non-verbal autistic child, attends the Center for Autism at Kiln Creek Elementary School. Through his father, he filed a lawsuit alleging that while being transported on a school bus, Newport News Public Schools employees struck him with a wet sock, verbally abused him, and allowed him to leave the bus partially unclothed. The complaint also mentioned previous verbal insults by school employees. Z.M. sought $15 million in compensatory and punitive damages, alleging negligence and gross negligence by the School Board and its employees.The Newport News School Board filed a plea in bar, claiming sovereign immunity. The Circuit Court of Newport News denied the plea regarding claims of simple and gross negligence but granted it concerning punitive damages, citing sovereign immunity. The School Board then filed an interlocutory appeal under Code §§ 8.01-626 and 8.01-670.2, which allow appeals from decisions on sovereign immunity pleas.The Supreme Court of Virginia reviewed the case de novo. The court concluded that Code § 22.1-194, which waives sovereign immunity when a vehicle is "involved in an accident," did not apply because the bus was not involved in an accident. The court held that the alleged acts did not relate to the operation of the bus as a vehicle. Consequently, the court reversed the circuit court's judgment and remanded the case for further proceedings. The court also noted that while the School Board is protected by sovereign immunity, the employees accused of gross negligence are not, allowing the lawsuit to proceed against them. View "Newport News School Board v. Z.M." on Justia Law

The case involves a divorce dispute between a husband and wife who married in 1993 and had two children. They lived in various locations, including Paris, France, due to the wife's job. In 2014, they moved to separate residences, with the wife claiming she intended to permanently separate and divorce her husband from that date. Despite participating in family activities together, the wife maintained that her intent to separate was continuous. The wife filed for divorce in 2019, citing a separation date of July 14, 2014, while the husband claimed the separation date was December 24, 2018, alleging adultery and desertion.The trial court ruled in favor of the wife, granting her a divorce based on the separation date of July 14, 2014. The husband appealed to the Court of Appeals of Virginia, arguing that the intent to permanently separate must be continuous throughout the statutory period. The Court of Appeals held that the intent only needed to exist at the beginning of the separation period, affirming the trial court's decision.The Supreme Court of Virginia reviewed the case and disagreed with the Court of Appeals' reasoning. The Supreme Court held that the intent to permanently separate must predominate throughout the statutory period, not just at the beginning. However, the Supreme Court affirmed the trial court's judgment, presuming that the trial court applied the correct standard and finding sufficient evidence to support the wife's continuous intent to separate. Thus, the Supreme Court affirmed the divorce decree on different grounds. View "Lisann v. Lisann" on Justia Law

Roscoe James Shaw was convicted of maliciously concealing a dead body in violation of Virginia law. Shaw and his partner, James Fisher, lived together in Arlington, Virginia. Fisher died under unclear circumstances, and Shaw kept Fisher's body in their apartment for three days. During this time, Shaw communicated with Moika Christopher Nduku and others about disposing of the body. Shaw also cleaned the apartment and attempted to remove evidence of Fisher's death. Eventually, a friend of Shaw's, Denise Barnes, discovered the body and called the police.The trial court excluded the testimony of Shaw's expert witness, Dr. Sara Boyd, who was to testify about Shaw's mental condition at the time of the offense. Dr. Boyd's testimony suggested that Shaw's mental illnesses, including PTSD and major depressive disorder, impaired his ability to form the necessary intent to commit the crime. The trial court found Dr. Boyd's testimony speculative and inadmissible. Shaw was convicted by a jury and appealed the decision.The Court of Appeals of Virginia affirmed Shaw's conviction, agreeing with the trial court's decision to exclude Dr. Boyd's testimony. The Court of Appeals held that Dr. Boyd's testimony did not sufficiently connect Shaw's mental condition to the specific intent required for the offense.The Supreme Court of Virginia reviewed the case and concluded that any error in excluding Dr. Boyd's testimony was harmless. The court found that the evidence of Shaw's guilt was overwhelming, including his actions and communications that demonstrated planning and intent to conceal Fisher's body. The court affirmed the judgment of the Court of Appeals, holding that Shaw's conviction should stand. View "Shaw v. Commonwealth" on Justia Law

In 2017, Silfredo Antonio Castillo Canales was convicted of statutory burglary and grand larceny, receiving concurrent five-year sentences with two years and six months suspended, and was placed on supervised probation. After his release in 2019, Castillo Canales violated probation terms multiple times, including failing drug tests, missing appointments, and not complying with his drug treatment program. These violations occurred over approximately five months, with periods of compliance in between.The Circuit Court of Arlington County held separate hearings for each violation, rejecting Castillo Canales' argument that all violations should be considered in a single hearing under Code § 19.2-306.1. The court found him guilty of several violations and imposed sentences, some of which included active incarceration.The Court of Appeals of Virginia affirmed the circuit court's decision to hold separate hearings but concluded that the violations constituted two courses of conduct. It ruled that Castillo Canales should have been sentenced as if he had committed only two technical violations, limiting his active incarceration to 14 days.The Supreme Court of Virginia reviewed the case and held that Code § 19.2-306.1 does not require all probation violations to be addressed in a single hearing. The court also determined that the circuit court reasonably found the violations to be separate and distinct events, not part of a "single course of conduct." Consequently, the Supreme Court affirmed the Court of Appeals' decision in part, reversed it in part, and reinstated the circuit court's judgment, allowing for more than 14 days of active incarceration for the violations addressed in the May 13, 2022 hearings. View "Commonwealth v. Canales" on Justia Law

Dennis Christopher Howard sued Spotsylvania County Sheriff Roger L. Harris and Deputy David Setlock for injuries from a self-inflicted gunshot wound while detained in a law enforcement vehicle. Howard claimed Harris was responsible for Setlock’s actions, which he argued constituted gross negligence. The incident began when Howard, a convicted felon, was found with a suicide note and missing shotgun. After being detained and searched, Howard maneuvered his handcuffs, accessed a handgun left in the vehicle, and shot himself.The Circuit Court of Spotsylvania County granted summary judgment for the defendants, ruling that Howard’s gross negligence claim failed as a matter of law and that the defense of illegality barred his claims. The court found that Setlock’s actions did not amount to gross negligence and that Howard’s injuries resulted from his illegal act of possessing a firearm as a convicted felon.The Court of Appeals of Virginia reversed the circuit court’s decision, holding that Howard had stated a viable gross negligence claim and that his claim was not barred by the illegality defense. The appellate court found that there was a genuine dispute of material fact regarding Howard’s mental state and whether it negated the mens rea required for the illegal possession of a firearm.The Supreme Court of Virginia reviewed the case and concluded that Howard’s claim was barred by the defense of illegality. The court held that Howard’s violation of Code § 18.2-308.2, which prohibits convicted felons from possessing firearms, was a proximate cause of his injuries. The court reversed the judgment of the Court of Appeals and entered final judgment for the defendants, finding that Howard’s allegation of an “unsound mind” did not negate the strict liability offense of possessing a firearm as a convicted felon. View "Harris v. Howard" on Justia Law