Justia Virginia Supreme Court Opinion Summaries

The case involves Montalla, LLC ("Montalla") and the Commonwealth of Virginia, Department of Transportation ("VDOT"), and the Comptroller of Virginia (collectively the "Commonwealth"). Montalla filed a five-count complaint against the Commonwealth related to several contracts VDOT had entered into for construction inspection services. The circuit court dismissed the entire complaint, ruling that sovereign immunity barred all five counts. The Court of Appeals affirmed the judgment of the circuit court, concluding that Counts I-III of the complaint were barred by sovereign immunity and that Counts IV-V were barred by the entry of a settlement agreement entered into by the pertinent parties.The Court of Appeals of Virginia affirmed the lower court's decision, concluding that the first three counts of the complaint were barred by sovereign immunity and that the last two counts were barred by the entry of a settlement agreement. The Court of Appeals reasoned that the settlement agreement was enforceable and that Montalla had not sufficiently alleged duress or repudiation to set it aside.The Supreme Court of Virginia reversed the judgment of the Court of Appeals. The Supreme Court held that the doctrine of sovereign immunity did not bar Montalla's claims based on valid contracts. The Court also held that the Court of Appeals erred in concluding that the settlement agreement, including the release of claims contained therein, was enforceable at this stage of the proceedings. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Montalla, LLC v. Commonwealth" on Justia Law

In Virginia, Bryant McCants arranged for his 1970 Ford Mustang Mach 1 to be repaired at a shop operated by CD & PB Enterprises, LLC, doing business as Maaco Collision Repair & Auto Painting. The repair shop was managed by Hanson Butler, a part owner and employee of CD & PB Maaco. After the work was completed, McCants inspected the vehicle and was unsatisfied with the work, prompting Butler to agree to repaint it. However, due to various personal circumstances, McCants was unable to pick up the vehicle for several months. In the meantime, Butler initiated the Virginia Department of Motor Vehicles' abandoned-vehicle process, which resulted in him acquiring title to the vehicle, which he later sold.McCants sued Butler for conversion, fraud, unjust enrichment, breach of contract, and violation of the Virginia Consumer Protection Act. The jury found in favor of McCants on the conversion claim only and awarded him $78,500. The Court of Appeals reversed the trial court's decision, finding that Butler had properly followed the abandoned-vehicle process and had obtained legal title to the vehicle.The Supreme Court of Virginia disagreed with the Court of Appeals, holding that a rational jury could have found that Butler wrongfully used the DMV's abandoned-vehicle process as a pretext for severing McCants's ownership rights in the vehicle and thereafter claiming it for himself. The Supreme Court reversed the judgment of the Court of Appeals, reinstated the jury’s verdict, and affirmed the trial court’s confirmation order. View "McCants v. CD & PB Enterprises, LLC" on Justia Law

The Supreme Court reversed the order of the circuit court entering summary judgment favor of Eastern Shore Community Services Board (ESCSB) and holding that Oreze Healthcare LLC's conveyance of real property to a third party prohibited Oreze from pursuing its breach of contract claim against ESCSB, holding that ESCSB was not entitled to summary judgment as a matter of law.ESCSB and Oreze entered into a commercial lease agreement under which ESCSB agreed to lease the four buildings comprising an assisted living facility whose license had been suspended and to provide interim care to its residents until a permanent solution was reached. When water damaged the buildings and no remedy was reached before ESCSB terminated the lease Oreze brought this complaint for breach of contract. While the lawsuit was pending, Oreze conveyed the property to a third party by general warranty deed. The circuit court granted summary judgment for ESCSB, ruling that Oreze failed to reserve its claims in the deed. The Supreme Court reversed, holding that the deed did not extinguish or transfer Oreze's right to sue ESCSB for property damage arising from an alleged breach of the lease. View "Oreze Healthcare v. Eastern Shore Community Services Bd." on Justia Law

The Supreme Court affirmed the judgment of the circuit court striking Arch Insurance Company's conversion and unjust enrichment claims, holding that the circuit court did not err in concluding that Arch was incapable of demonstrating a priority right to the disputed funds at issue in this case as a matter of law.FVCbank provided Dominion Mechanical Contractors, Inc. with a revolving line of credit. Arch, a surety company, issued contract surety bonds for some of Dominion's projects. Due to Dominion's later financial troubles, FVCbank froze Dominion's accounts. Arch and Dominion sued, claiming conversion and unjust enrichment. The circuit court granted FVCbank's motion to strike Arch's claims, finding that because FVCbank had a priority interest in Dominion's accounts, there was no legal claim for unjust enrichment or conversion. The circuit court affirmed, holding that the circuit court (1) correctly concluded that FVCbank's interest in Dominion's deposit accounts took priority over Arch's interest as a matter of law; and (2) properly dismissed the claims with prejudice. View "Arch Insurance Co. v. FVCbank" on Justia Law

The Supreme Court reversed the decision of the circuit court determining that an auctioneer had verbally modified its advertised terms prior to the start of the auction and ordering the conveyance of a fee simple interest in a parcel of real property by special warranty deed to Plaintiff, holding that the circuit court erred.Plaintiff attended an auction advertised by Plaintiff for the sale of the property at issue. Plaintiff's bid was the high bid, but Defendants refused to sell the property for that amount. Plaintiff brought this complaint seeking specific performance, alleging that, in the pre-auction announcement, Defendants used language stating that the auction was going to be an absolute auction. The trial court ruled that Plaintiff was entitled to specific performance and ordered the conveyance of the property by special warranty deed. The Supreme Court reversed, holding (1) the trial court erred in ruling that the auction was an absolute auction rather than an auction with reserve; and (2) therefore, no contract was formed between the parties. View "Williams v. Janson" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing Ashland, LLC's claim against Virginia-American Water Company for an alleged breach of contract, holding that the circuit court erred in concluding that Va. Const. art. IX, 4 deprived it of jurisdiction to adjudicate Ashland's contract claim.Ashland filed suit against Virginia-American, which provided water to Ashland pursuant to a tariff issued by the State Corporation Commission, after a power outage disrupted water service to Ashland, resulting in $515,000 in damages due to lost business and profits. Ashland's complaint asserted a breach of contract claim based on an alleged violation of the tariff. The circuit court concluded that the promulgation of a tariff by the Commission is an action of the Commission, and therefore, the circuit court lacked jurisdiction. The Supreme Court reversed, holding that circuit courts are free to read and then apply the terms of a tariff as adopted by the Commission as necessary to resolve a common law dispute. View "Ashland, LLC v. Virginia-American Water Co." on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the judgment of the circuit court awarding sanctions against Plaintiffs, holding that the circuit court erred in awarding the total amount of the attorney's fees claimed.Plaintiffs brought this claim alleging fraud, breach of fiduciary duty, tortious interference with a contractual relationship or business expectancy, and business conspiracy against Defendant, a former employee. After the circuit court granted Plaintiffs' motions to nonsuit as to all parties the circuit court granted Defendant's motion for sanctions, awarding sanctions of $213,197 - Defendant's total attorney's fees - against Plaintiffs. The Supreme Court reversed in part, holding that the circuit court (1) was within its discretion to award sanctions against Plaintiffs; but (2) erred in awarding sanctions for certain conduct and in failing to segregate sanctionable claim from the attorney's fees requested. View "AV Automotive, LLC v. Gebreyessus" on Justia Law

The Supreme Court held that the Virginia Uniform Arbitration Act, Va. Code 8.01-581.01 to -.016 (VUAA), and the Federal Arbitration Act, 9 U.S.C. 1-16 (FAA), do not compel enforcement of an arbitration clause in a trust.The decedent created an inter vivos irrevocable trust that was divided into three shares for his children and grandchildren. The trust contained an unambiguous arbitration clause. Plaintiff filed a complaint against Defendant, the trust's trustee, alleging breach of duty. Defendant filed a motion to compel arbitration, which the circuit court denied. The Supreme Court affirmed, holding (1) a trust is neither a contract nor an agreement that can be enforced against a beneficiary; and (2) therefore, neither the VUAA nor the FAA compel arbitration. View "Boyle v. Anderson" on Justia Law

The Supreme Court held that the circuit court erred in this case in awarding SustainedMED, LLC attorneys' fees as well as expenses and costs in excess of $24,999.94 on its indemnification claim because the award exceeded the maximum indemnification amount allowed under an indemnity agreement.Sellers entered into a stock purchase agreement (SPA) for the sale of their collective shares in Cyfluent, Inc. to SustainedMED. The total purchase price for the sale of the Cyfluent stock was $4,900,000. The SPA included an indemnity agreement requiring Sellers to indemnify Sustained MED for losses resulting from inaccuracies in or breach of any representations or warranties made by Sellers. SustainedMED filed suit against Sellers alleging misrepresentations and fraud in the inducement. The circuit court ruled in favor of SustainedMED and awarded SustainedMED $972,323.50 in attorneys' fees and $64,225 in litigation expenses and costs. The Supreme Court reversed as to the award of attorneys' fees and costs, holding that the circuit court erred in awarding attorneys' fees and costs in excess of $24,999.94 on SustainedMED's indemnification claim because of the SPA's indemnification cap of $4,900,000. View "Ehrhardt v. SustainedMED, LLC" on Justia Law

The Supreme Court affirmed the decision of the State Corporation Commission finding that a pumped storage hydroelectric facility (or pumped storage) generates "renewable energy" under the former definition in Va. Code 56-576 and that the amended definition would not apply to contracts executed before the amendment's effective date, holding that there was no error.The Commission concluded that pumped storage satisfied the statutory definition of renewable energy in effect at the time that the service provider executed its contracts and declined to find that the amended definition would apply retroactively to contracts executed before the amendment's effective date. The Supreme Court affirmed, holding (1) the Commission did not err in its interpretation of the statute or its finding that pumped storage satisfied the former definition of renewable energy; and (2) the Commission did not err in refusing retroactively to apply the amended statutory definition of renewable energy to the service provider's contracts that were executed before the amendment took effect. View "Virginia Electric & Power Co. v. State Corporation Commission" on Justia Law