Justia Virginia Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the circuit court denying Defendant’s motion for continuance pursuant to Va. Code 19.2-159.1, holding that there was no reversible error in the court of appeals’ judgment.Defendant pled guilty to a single charge of robbery. At a sentencing hearing, Defendant sought and was granted a continuance to July 15. On July 14, Defendant filed a motion to substitute counsel and also sought a continuance pursuant to section 19.2-159.1. The circuit court declined to substitute counsel and denied the motion for continuance. The court of appeals affirmed, ruling that Defendant failed to demonstrate exceptional circumstances to obtain a last-minute continuance. On appeal, Defendant asserted that section 19.2-159.1 required him to obtain private counsel, which he had done, and that he was therefore entitled to a continuance. The Supreme Court disagreed, holding that the statute confers no rights on defendants, and therefore, defendants are entitled to no remedy if a court declines to substitute counsel and grant a continuance for counsel to prepare. View "Reyes v. Commonwealth" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant’s petition for writ of actual innocence based on nonbiological evidence, holding that the court of appeal abused its discretion in refusing to order an evidentiary hearing before denying the petition.The petition in this case and its supporting evidence raised substantial factual questions. The court of appeals resolved those questions on the record without referring any issues to a circuit court for an evidentiary hearing, holding that Appellant failed to demonstrate that the evidence upon which he relied was material. The Supreme Court reversed, holding that the court of appeals abused its discretion by determining that the facts in this case did not require further development in a circuit court evidentiary hearing. View "Dennis v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the decision of the Virginia Workers’ Compensation Commission not to award Appellant benefits after he was injured while renovating a historic school building, holding that Appellant did not meet his burden of proving his statutory-employer claim for workers’ compensation benefits.Appellant sought benefits against a church and its historical society, alleging that these entities were his statutory employers. The Commission denied benefits, holding that none of the defendants were Appellant’s direct employer and that the church and the historical society were not Appellant’s statutory employers. The court of appeals affirmed. The Supreme Court affirmed, holding that the Commission applied the correct legal standard and acted within its fact-finding discretion in concluding that Appellant had failed to prove that the church or the historical society were his statutory employers. View "Jeffreys v. Uninsured Employer's Fund" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment in favor of the Tax Department on the Corporate Executive Board Company’s (CEB) complaint alleging that its income tax assessments violated the “dormant” Commerce Clause and the Due Process Clause of the United States Constitution and that the assessments were “inequitable” under the Tax Department’s regulations, holding that the circuit court did not err in declining to grant relief.CEB sought relief from the assessments for the years 2011, 2012, and 2013 and requested a redetermination of its income tax. The circuit court found in favor of the Tax Department. The Supreme Court affirmed, holding (1) the Tax Department’s apportionment of CEB’s income tax was in accord with constitutional requirements; and (2) the regulation allowing relief did not apply under its plain language. View "The Corporate Executive Board Co. v. Department of Taxation" on Justia Law

In this appeal by a railroad corporation (Defendant) from a judgment in favor of one of its employees (Plaintiff) in an action brought under the Federal Employers’ Liability Act (FELA), 45 U.S.C. 51 through 59, the Supreme Court affirmed the judgment of the circuit court, holding that the circuit court did not err in admitting certain testimony or in granting Defendant’s motions to strike and to set aside the verdict.After a jury trial, the circuit court entered judgment on the verdict and awarded Plaintiff damages. The Supreme Court affirmed, holding (1) there was no merit to Defendant’s argument that the circuit court erred in admitting expert testimony; and (2) the evidence was sufficient to create a jury issue with regard to causation, and, armed with a jury verdict in his favor approved by the trial court, Plaintiff was entitled to have the evidence and the inferences reasonably drawn from it viewed in the light most favorable to him. View "Norfolk Southern Railway Co. v. Sumner" on Justia Law

The Supreme Court reversed the decision of the circuit court holding that EPC MD 15, LLC’s ability to control its subsidiary meant that, for insurance-coverage purposes, EPC acquired all of the subsidiary’s property under a coverage-extension provision in the commercial property policy issued by Erie Insurance Exchange, holding that the circuit court misinterpreted the coverage-extension provision in the policy.EPC was a named insurance on the policy issued by Erie. EPC claimed coverage for fire damages to a building owned by one of EPC’s subsidiaries, but the subsidiary was not a named insured, and no provision of the policy identified the subsidiary as an additional insured. The circuit court found that coverage existed for the loss and entered final judgment for EPC. The Supreme Court reversed, holding that the Erie policy did not cover the damaged property in this case. View "Erie Insurance Exchange v. EPC MD 15, LLC" on Justia Law

The Supreme Court reversed the judgment of the circuit court finding that laches barred Plaintiff’s motion for a temporary injunction, sustaining a special plea in bar, and entering judgment in favor of a Corporation, holding that the circuit court erred in its interpretation of Va. Code. 13.1-724.Plaintiff sought a declaratory judgment that a letter of intent to sell assets of the Corporation to a third party buyer for $10 million were null and void because they violated section 13.1-724, which requires more than two-thirds shareholder approval for a disposition of of corporate assets that leaves a corporation without a significant continuing business. Plaintiff also sought a temporary injunction to stop the proposed sale until the circuit court could address the merits of the complaint. The Corporation responded by filing a special plea in bar. The circuit court denied Plaintiff’s emergency motion for an injunction, granting the plea in bar, and entered judgment in favor of the Corporation. The Supreme Court reversed, holding (1) the circuit court erred in its interpretation of section 13.1-724 and thus erred in entering judgment in favor of the Corporation; and (2) the circuit court abused its discretion when it found that laches barred Plaintiff’s request for a temporary injunction. View "May v. R.A. Yancey Lumber Corp." on Justia Law

The Supreme Court reversed the trial court’s determination that Defendant’s motion filed pursuant to the safety value provision of Va. Code 18.2-248(C), which provides potential relief from mandatory minimum sentences according to certain terms, was untimely and declining to rule on the merits, holding that the motion was timely and warranted consideration on the merits.The safety value provision provides for relief from mandatory sentences when the defendant truthfully provides all information and evidence concerning his offense to the Commonwealth not later than the time of the sentencing hearing. In this case, Defendant provided the required information concerning his offense immediately prior to the sentencing hearing. The trial court denied the motion, and Defendant received the mandatory sentences. The Supreme Court reversed, holding that disclosure was timely made to the Commonwealth, and therefore, the motion warranted consideration on the merits for the completeness and truthfulness of the disclosure as well as any further disclosure made to the Commonwealth before resentencing. View "Hall v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant’s motion to amend her complaint to name the personal representative of her deceased husband’s estate as the proper party defendant and dismissing the action as time-barred, holding that the circuit court did not err.The decedent executed a holographic will that excluded his wife, Ray, as a beneficiary of his estate. Following her husband’s death, Appellant filed an action to claim her elective share of the augmented estate. The administratrix of the estate was not named as a party to the action. When Appellant realized the error, she requested that the circuit court enter an order adding the administratrix to the complaint as a party defendant. The circuit court denied the motion and dismissed the action as time-barred. The Supreme Court affirmed, holding (1) Appellant failed to identify the proper party defendant in the complaint as filed; and (2) Appellant was time-barred from bringing a new and proper action against the estate’s personal representative. View "Ray v. Ready" on Justia Law

The Supreme Court reversed the decision of the circuit court in sustaining the demurrer filed by ALG Trustee, LLC and dismissing Appellant’s second complaint with prejudice, holding that Appellant’s allegations were sufficient to survive a demurrer.Appellant alleged in this complaint that ALG Trustee had breached its fiduciary duty as trustee under a deed of trust. Ultimately, the trial court sustained the demurrer filed by ALG Trustee. The Supreme Court reversed, holding (1) the trial court erred in mischaracterizing Appellant’s claim as a common law negligence claim because Appellant’s claim sounded in contract, not tort; and (2) the trial court erred in concluding that ALG Trustees had no duties beyond those set forth in the deed of trust. View "Crosby v. ALG Trustee, LLC" on Justia Law