Justia Virginia Supreme Court Opinion Summaries

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

Fatima Shaw-McDonald filed a medical malpractice lawsuit against Eye Consultants of Northern Virginia, P.C. after suffering vision loss following cataract surgery. While the lawsuit was pending, she filed for Chapter 7 bankruptcy but did not initially disclose the lawsuit in her bankruptcy filings. Eye Consultants moved to dismiss the lawsuit, arguing that Shaw-McDonald no longer had standing to pursue it because her interest in the lawsuit had transferred to the bankruptcy trustee. Shaw-McDonald later amended her bankruptcy filings to include the lawsuit and obtained a discharge from the bankruptcy court.The circuit court dismissed the medical malpractice case, concluding that Shaw-McDonald lost standing when she filed for bankruptcy. The court relied on the precedent set by Kocher v. Campbell, which held that a plaintiff loses standing when a cause of action becomes part of the bankruptcy estate. Shaw-McDonald appealed the decision.The Court of Appeals of Virginia reversed the circuit court's decision, holding that Shaw-McDonald had standing to maintain her medical malpractice action. The court reasoned that once the bankruptcy trustee abandoned the claim, it reverted to Shaw-McDonald as if no bankruptcy petition had been filed.The Supreme Court of Virginia reviewed the case and affirmed the Court of Appeals' decision. The court held that Shaw-McDonald did not lose standing permanently when she filed for bankruptcy; rather, her standing was temporarily suspended. The court concluded that the appropriate remedy was to hold the medical malpractice case in abeyance until the bankruptcy proceedings were resolved, rather than dismissing it. The case was remanded to the Court of Appeals for further proceedings consistent with this opinion. View "Eye Consultants of Northern Virginia P.C. v. Shaw-McDonald" on Justia Law

Sycamore Cross Solar LLC applied for certificates of public convenience and necessity (CPCN) to construct and operate a solar facility in Isle of Wight County and Surry County, Virginia. The project aimed to generate up to 240 megawatts of power and included transmission lines and associated facilities. The West Virginia & Appalachian Laborers’ District Council (WVALDC) participated in the case, arguing that the State Corporation Commission (Commission) failed to consider the benefits to specific groups as required by the Virginia Clean Economy Act (VCEA) and did not impose a local hiring condition.The Commission conducted an evidentiary hearing where Sycamore, WVALDC, and Commission staff presented their cases. Sycamore's witness testified about the project's economic benefits and commitment to local hiring, though no firm commitment was made. The Hearing Examiner recommended issuing the CPCNs without a local hiring condition but suggested notifying WVALDC about hiring timelines. The Commission adopted the Hearing Examiner's findings but declined the notification requirement, leading WVALDC to seek reconsideration.The Supreme Court of Virginia reviewed the case and affirmed the Commission's decision. The Court held that the VCEA only required the Commission to consider the benefits to specified groups, not make specific findings. The Commission's consideration of the evidence and its decision not to impose a hiring-related condition were within its discretion. The Court found no abuse of discretion, as the Commission reasonably concluded that the statutory requirements were met without the need for additional hiring conditions. View "WVALDC v. State Corporation Commission" on Justia Law