Justia Virginia Supreme Court Opinion Summaries

Tanisha Bates was indicted for arson. The circuit court found Bates not guilty by reason of insanity. Subsequently, the circuit court concluded that Bates was in need of inpatient hospitalization and committed her to the custody of the Commissioner of Mental Health, Mental Retardation and Substance Abuse Services. The Supreme Court affirmed, holding that the circuit court did not err when it determined that the particular circumstances warranted Bates’ commitment to inpatient hospitalization rather than to conditional release because it correctly applied the standards articulated in Va. Code Ann. 19.2-182.3 and 19.2-182.7 to the present case. View "Bates v. Commonwealth" on Justia Law

At issue in this appeal was whether the circuit court erred in allowing Plaintiff to take a nonsuit as a matter of right pursuant to Va. Code Ann. 8.01-380(B) based on its determination that Plaintiff's prior voluntary dismissal in federal court was not a nonsuit under section 8.01-380. In Virginia, a plaintiff may take only one nonsuit as a matter of right. The Supreme Court affirmed, holding that the trial court did not err in finding that Plaintiff was permitted to take a nonsuit as a matter of right pursuant to section 8.01-380(B), holding (1) Va. Code Ann. 8.01-229(E)(3) does not confirm or suggest that a voluntary dismissal taken pursuant to Fed. R. Civ. P. 41(a)(1)(A)(i) is a nonsuit for purposes of section 8.01-380; and (2) Plaintiff's prior voluntary dismissal in federal court was not substantially equivalent to Virginia's nonsuit in this regard. View "Inova Health Care Servs. v. Kebaish" on Justia Law

Maritess Lopez died from aspiration pneumonia secondary to a surgery performed by Dr. Matthew Galumbeck. Plaintiff, Lopez's husband, brought a wrongful-death action against Galumbeck, another doctor, and Plastic Surgery of Tidewater. The trial entered judgment in favor of Plaintiff. Galumbeck appealed. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in (1) denying Galumbeck's motion for a mistrial due to a juror's alleged misconduct; and (2) admitting unpaid medical bills into evidence. The Court additionally held that Galumbeck's assertions that the trial court erred in prohibiting him from introducing a surgical log into evidence or from using it to refresh a nurse's recollection and in allowing testimony and evidence on a collateral matter were not preserved for appeal. View "Galumbeck v. Lopez" on Justia Law

Jean Moreau & Associates brought this suit against the Health Center Commission for the County of Chesterfield (HCC), a municipal corporation, seeking a declaratory judgment and alleging claims for breach of contract and quantum meruit. The circuit court dismissed Jean Moreau's claims. The Supreme Court affirmed, holding (1) because Jean Moreau did not comply with the mandatory procedural requirements of the Virginia Public Procurement Act in bringing its breach of contract claim against HCC, the circuit court did not err in concluding that the claim was barred; and (2) the circuit court did not err in concluding that Jean Moreau's quantum meruit claim was barred by the doctrine of sovereign immunity for HCC's development and operation of Springdale, an independent living facility, because (i) municipal corporations performing governmental functions are immune from quantum meruit claims, (ii) HCC was not entitled to absolute immunity simply because it was created by a county and not a municipality, but (iii) Springdale served a governmental function. View "Jean Moreau & Assocs., Inc. v. Health Ctr. Comm'n" on Justia Law