Justia Virginia Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court concluding that Plaintiff lacked standing to enforce the "midnight deadline" rule set forth in section 4-302 of the Uniform Commercial Code (UCC), as adopted by Va. Code 8.4-302 and W. Va. Code 46-4-302, holding that there was no error.In her second amended complaint, Plaintiff alleged that MCNB Bank and Trust Company (MCNB) violated the midnight deadline rule adopted from the UCC and, therefore, MCNB was strictly liable for the payment of a check in the amount of $245,271.25. The circuit court granted summary judgment for MCNB, concluding that Plaintiff lacked standing to pursue her claim because she did not have any right to rely on the prompt payment of the check at issue. The Supreme Court affirmed, holding that the circuit court did not err when it granted MCNB’s motion for summary judgment based on Plaintiff's alleged lack of standing to enforce the midnight deadline rule. View "Stahl v. Stitt" on Justia Law

The Supreme Court affirmed the judgment of the circuit court determining what portion of a settlement was subject to the Commonwealth's Medicaid lien, holding that there was no error.Appellant was seriously injured in a car accident. Because the Commonwealth's Medicaid program paid for a portion of Appellant's medical care the Commonwealth was entitled to a lien on the proceeds of an ensuing settlement between Appellant and the driver who caused the accident. At issue was what portion of the settlement was subject to the Medicaid lien. The Supreme Court affirmed, holding that the circuit court's judgment was proper under the deferential standard. View "Farah v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court holding that the Virginia Department of Taxation's corporation income tax assessments for the years in issue were erroneous and ordering the Department to refund Lorillard Tobacco Company the amount of its overpayments on the assessments for the years in issue, holding that there was no error.Lorillard filed an application for correction of erroneous assessment of corporation income taxes challenging the denial of its refund claims for certain assessments. The circuit court held that the Department's assessments were erroneous and ordered the Department to correct the assessments by refunding Lorillard the amount of its overpayments. The Supreme Court affirmed, holding that the circuit court did not err. View "Virginia Department of Taxation v. R.J. Reynolds Tobacco" on Justia Law

The Supreme Court granted Daniel Rothstein's motion to dismiss the appeal brought by Robert Godlove and Theresa Wolfe (together, Appellants) and vacated the judgment of the trial court in favor of Rothstein, holding that this case was moot.The trial court interpreted a deed of dedication as permitting Rothstein to extend a paved driveway within an easement running across Appellants' property to Rothstein's property. After Appellants filed a notice of appeal, Rothstein filed a motion to dismiss the appeal as moot. The Supreme Court granted the motion and vacated the judgment, holding that there was no longer any live controversy. View "Godlove v. Rothstein" on Justia Law

The Supreme Court affirmed Defendant's conviction for rape, holding that Defendant did not suffer any violation of his rights under the Confrontation Clause of the United States Constitution.On appeal, Defendant argued that the prosecution violated his right to confrontation by failing to produce as a witness a police officer who translated for a police detective at the crime scene. At trial, the Commonwealth offered the testimony of a different police officer who, separately, translated the exchange between Defendant and the detective. The Supreme Court affirmed, holding that there was no constitutional requirement for the officer at issue to be confronted at trial. View "Cortez-Rivas v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the revocation of Defendant's deferred disposition and conviction for possession of heroin due to Defendant's failure to pay court costs, holding that there was no error.Pursuant to a plea agreement, Defendant pleaded guilty to possession of heroin. The agreement specified that Defendant would pay all court costs and the costs of any programs ordered by Defendant's probation officer. The circuit court deferred its finding that the facts were sufficient for a finding of guilt for one year subject to the terms and conditions in the plea agreement. The court further ordered that Defendant pay the costs of prosecution. The circuit court subsequently revoked Defendant's deferred disposition and adjudicated him guilty for failure to pay his court costs. The Supreme Court affirmed, holding that the circuit court did not err. View "Smallwood v. Commonwealth" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing a bill of review after determining that the underlying matter was an action at law and that a bill of review was inappropriate, holding that the circuit court erred.The City of Petersburg brought an action against the Emmanuel Worship Center and its trustees (collectively, EWC) for delinquent taxes. The circuit court found that EWC owed the City for delinquent real estate taxes and then issued a decree of sale. EWC paid to redeem its property and then filed a bill of review seeking reversal or modification of the decree of sale and an award of the amounts it had paid to the City, arguing that it was constitutionally exempt from paying real estate taxes because the property was owned and used exclusively for religious purposes. The circuit court denied the bill of review. The Supreme Court reversed and remanded the case for further proceedings, holding that the circuit court (1) erred in determining that the underlying action was an action at law, and (2) erred in holding that because more than three years had passed since the taxes were assessed they were beyond review. View "Emmanuel Worship Center v. City of Petersburg" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction for conspiracy to distribute a controlled substance and reinstated that conviction, holding that the court of appeals erred in reversing Defendant's conviction for conspiracy.In reversing Defendant's conviction, the court of appeals ruled that the circuit court abused its discretion in denying two proffered jury instructions regarding the single-buyer/seller relationship exception to conspiracy liability. The Supreme Court reversed, holding that the circuit court did not abuse its discretion in denying the proffered jury instructions concerning a single-buyer/seller relationship. View "Commonwealth v. Richard" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the circuit court ruling that Marion Life Saving Crew, Inc. (MLSC) and its paramedics were entitled to statutory immunity pursuant to Va. Code 8.01-255(A)(5), holding that the circuit court erred in ruling that MLSC was immune from liability.Plaintiff, the administrator of the Estate of Calvin Harmon Shoots, brought this wrongful death complaint alleging that Defendants' grossly negligent conduct was the direct and proximate cause of the premature death of Shoots. The circuit court ruled (1) the paramedics were clearly negligent but that they were absolutely immune from liability under section 8.01-225(A)(5); and (2) MLSC was immune because the paramedics were immune from liability. The Supreme Court affirmed in part and reversed in part, holding (1) the circuit court correctly ruled that the paramedics were immune from liability; but (2) the paramedics' immunity from civil liability was not dispositive of whether section 8.01-225 applied to MLSC, and therefore, the circuit court erred in ruling that MLSC was immune because the paramedics were also immune. View "Stoots v. Marion Life Saving Crew, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of battering a police officer under Va. Code 18.2-57(C), holding that Defendant's contentions on appeal were without merit.Defendant was charged with assault and battery on a police officer, a felony. At trial, Defendant argued that she had used force to expel a trespasser, and therefore, her use of force was not unlawful. The court of appeals affirmed, concluding that the convictions was supported by sufficient evidence. The Supreme Court affirmed, holding that the circuit court did not err in concluding that Defendant's use of force was not justified by the law of trespass. View "Carter v. Commonwealth" on Justia Law