Justia Virginia Supreme Court Opinion Summaries

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

In 1994, Michael Haas was convicted at a bench trial in the circuit court of sodomy committed upon his two sons in 1992 and 1993, when they were eleven and nine years of age, respectively. After Haas' petition for writ of habeas corpus was denied, Hass filed a petition for a writ of actual innocence based on non-biological evidence, including recantation evidence. The court of appeals denied Haas' request to refer the case to the circuit court for an evidentiary hearing and dismissed the petition. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in (1) declining to refer the case back to the circuit court for an evidentiary hearing, and (2) finding that Haas failed to carry his burden of proof and, accordingly, granting the Commonwealth's motion to dismiss his petition. View "Haas v. Commonwealth" on Justia Law

Linda Eberhardt, an employee of the Fairfax County School Board and a member of the Fairfax County Employees' Retirement Systems (FCERS), was injured during the course of her employment. Eberhardt applied for service-connected disability retirement benefits. The FCERS Board of Trustees denied Eberhardt's application for service-connected disability retirement benefits but awarded ordinary disability retirement benefits. Eberhardt appealed under Va. Code Ann. 51.1-823. The Board filed a motion to dismiss, asserting that the circuit court lacked subject-matter jurisdiction to hear the appeal because section 51.1-823 applied only to police officers' retirement systems in counties with the urban executive form of government. The court granted the motion. The Supreme Court affirmed, holding that the circuit court correctly ruled that section 51.1-823 did not confer jurisdiction upon it to hear Eberhardt's appeal because the word "board" as used in section 51.1-823 did not encompass the board of any retirement system created by a county having an urban executive form of government. View "Eberhardt v. Fairfax County Employees' Ret. Sys. Bd. of Trs." on Justia Law

An unincorporated association purporting to represent the general public filed a complaint for injunctive relief against several property owners, alleging that the property owners blocked access to a public road by the general public by erecting pole gates. In their answer, the property owners denied that the road was a public road. The circuit court granted injunctive relief to the association after finding that the association had proven that the general public was entitled to unrestricted use of the road. The Supreme Court reversed, holding (1) the circuit court did not err in finding there had been no dedication and acceptance of the road as a public road; (2) the circuit court erred in finding that the association had established that the road was public solely by virtue of its long and continuous use by the general public and recognition of that use by the county; and (3) the circuit court erred in its ruling insofar as it would allow a traditional prescriptive easement could be created in favor of the general public, but the court's ruling that prescription had not been proven was nonetheless a correct result in light of its finding that there had been no acceptance. View "Dykes v. Friends of the C.C.C. Road" on Justia Law

Pursuant to a guilty plea, Steven DeMille was convicted of rape. Before DeMille's release from incarceration, the attorney general filed a petition seeking the civil commitment of DeMille as a sexually violent predator. After a bench trial, the circuit court entered an order declaring DeMille to be a sexually violent predator. At issue on appeal was whether in a proceeding under the Civil Commitment of Sexually Violent Predators Act, the determination that the respondent is likely to engage in sexually violent acts must be based solely on expert testimony that states an opinion to that effect in express terms. The Supreme Court affirmed, holding that the factual determination of whether a respondent is a sexually violent predator likely to engage in sexually violent acts is to be based on the totality of the record, including but not limited to expert testimony. View "DeMille v. Commonwealth" on Justia Law

Following a bench trial, the circuit court found Jerrod Quarles guilty of robbery and conspiracy to commit robbery. The court of appeals reversed, holding that the circuit court erred in denying Quarles' motion to suppress where the police impermissibly reinitiated communication with Quarles after he invoked his right to counsel in violation of his rights under the Fifth Amendment, and therefore, Quarles' subsequent waiver of his Miranda rights was not voluntary. The Supreme Court reversed, holding that the circuit court did not err in denying Quarles' motion to suppress where the police officer would not have known that Quarles was likely to respond to his statement and Quarles was not particularly susceptible to exposure to such statements. View "Commonwealth v. Quarles" on Justia Law

At issue in this appeal was whether a bail bondsman licensed in another state but not in Virginia had the authority to enter Virginia and apprehend a fugitive bailee. In a bench trial, Defendant, an out-of-state bail bondsman, was convicted of attempted abduction and use of a firearm in the commission of a felony. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the General Assembly plainly manifested its intent to abrogate the common law rule allowing out-of-state bail bondsmen and bounty hunters to enter Virginia to apprehend fugitive bailees; and (2) there was sufficient evidence to establish the specific intent necessary to support a conviction of attempted abduction. View "Collins v. Commonwealth" on Justia Law

Geographic Services, Inc. (GSI) hired Anthony Collelo for work that exposed Collelo to confidential information and alleged trade secrets. GSI and Collelo executed an employment agreement that included a non-disclosure provision prohibiting Collelo from disclosing GSI's confidential information. Collelo later resigned from GSI and was hired by Boeing. GSI subsequently filed suit against Boeing, Autometric, a wholly-owned subsidiary of Boeing, and Collelo (collectively, Defendants), alleging breach of contract, violation of the Trade Secrets Act, and tortious interference with GSI's contract with Collelo. The trial court granted Defendants' motion to strike and dismissed GSI's entire case with prejudice. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court erred when it dismissed GSI's claims under the Trade Secrets Act; (2) the trial court did not err when it dismissed GI's remaining claims; and (3) the trial court did not err when it denied Collelo's motion for attorneys' fees in relation to GSI's breach of contract claim. Remanded for a new trial on GSI's claims under the Trade Secrets Act. View "Collelo v. Geographic Services, Inc." on Justia Law

In this action, the trial court granted summary judgment against a locality, holding it liable to landowners under the State Water Control Law, Va. Code Ann. 62.1-44.2 through -44.34:28, in particular Code 62.1-44.34:18(C) of the Oil Discharge Law, for the contamination of groundwater by leachate and landfill gas. The Supreme Court reversed the trial court's judgment, holding that the trial court erred in awarding summary judgment to the landowners and finding the locality liable under the Oil Discharge Law, as the Oil Discharge Law does not apply to the passive, gradual seepage of leachate and landfill gas into groundwater. View "Campbell County v. Royal" on Justia Law

At a bench trial, the circuit court found Curtis Branham guilty of possession of cocaine with intent to distribute. The court of appeals affirmed. Branham appealed, arguing that the circuit court erred in denying his motion to suppress the Commonwealth's evidence on Fourth Amendment grounds. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Branham's motion to suppress where the arresting officer's search of Branham's person and vehicle and the results of those searches were not fruits of an unlawful seizure in violation of the Fourth Amendment; and (2) the circuit court did not err in admitting the certificate of analysis of the cocaine into evidence where the chain of custody evidence was sufficient. View "Branham v. Commonwealth" on Justia Law