Latest 6 Cases: VACORP v. Young (Contracts), Musgrove Construction Co. v. Young (Contracts), Caldwell v. Commonwealth (Criminal Law)

How Allen v. Cooper Breaks Important New (if Dubious) Ground on Stare Decisis

VIKRAM DAVID AMAR

Illinois Law dean and professor Vikram David Amar comments on language in a recent U.S. Supreme Court decision, Allen v. Cooperdiscussing constitutional stare decisis in the context of state sovereign immunity. Amar points out some of the problems with the Court’s jurisprudence on state sovereign immunity and Congress’s Section 5 power, and he questions the Allen majority’s embrace of a “special justification” requirement for constitutional stare decisis.

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VACORP v. Young

Docket: 190356

Opinion Date: April 9, 2020

Judge: McCullough

Areas of Law: Contracts, Insurance Law, Personal Injury

The Supreme Court affirmed the judgment of the trial court declaring that the School the City of Richmond's School Board's UM/UIM motorist coverage was $1 million, as provided in the contract between the School Board and the Virginia Association of Counties Group Self-Insurance Risk Pool (VACORP), holding that the $1 million in UM/UIM coverage the School Board contracted for was the amount of available UM/UIM coverage. Maisia Young was injured while riding a school bus. Young filed suit against the School Board seeking damages for her personal injuries. The School Board was self-insured through a self-insurance risk pool managed by VACORP. Young filed a declaratory judgment action to determine the extent of the coverage available to the School Board under the UM/UIM provisions of its contract. VACORP argued that $50,000 was the maximum amount of coverage available, as set by statute. In response, Young argued that the statutes set a minimum, not a cap, and that the maximum available was what was specified in the contract. The circuit court agreed with Young. The Supreme Court affirmed, holding that the School Board's UM/UIM coverage was $1 million, as provided in the contract between the School Board and VACORP.

Musgrove Construction Co. v. Young

Docket: 190180

Opinion Date: April 9, 2020

Judge: McCullough

Areas of Law: Contracts

The Supreme Court affirmed in part and reversed in part the judgment of the trial court awarding FoxFire Towing damages in the amount of $56,595, holding that the doctrine of quantum merit was not applicable in this case and that while FoxFire was entitled to relief under a theory of unjust enrichment it was only to the extent that T. Musgrove Construction Company was benefitted. Musgrove owned a truck that was involved in an accident. FoxFire returned the truck to an upright position, towed the damaged truck away and stored it, and cleaned up the scene. FoxFire sent Musgrove a bill for $12,380. When Musgrove did not pay, FoxFire sued. By the time the suit was filed the storage fees had risen to $28,980. The jury returned a verdict in the amount of $56,595. Musgrove appealed, arguing that most of the charges FoxFire impressed were unjustified because they constituted a recovery that was not warranted under the doctrine of unjust enrichment. The Supreme Court reversed in part, holding (1) a cause of action for quantum merit did not apply; and (2) established principles governing the unjust enrichment remedy foreclosed recovery for some of the charges FoxFire sought to obtain.

Caldwell v. Commonwealth

Docket: 190541

Opinion Date: April 9, 2020

Judge: LeRoy F. Millette, Jr.

Areas of Law: Criminal Law

The Supreme Court reversed Defendant's conviction of defrauding a hotel restaurant when she obtained food from the restaurant without paying, holding that a rational trier of fact could not have found the essential elements of the crime beyond a reasonable doubt. Defendant was convicted of violating Va. Code 18.2-188(b)(2), which makes it unlawful for any person who "without paying therefor, and with the intent to cheat or defraud the owner or keeper to...obtain food from a restaurant or other eating house." On appeal, Defendant argued that the plain language of section 18.2-188(b)(2) requires proof of specific intent to defraud at the time the benefit is received and that the Commonwealth's evidence was insufficient to prove she possessed the intent to defraud at the time she obtained the meal. The court of appeals affirmed. The Supreme Court reversed, holding (1) section 18.2-188(b)(2) required proof that Defendant had the intent to cheat or defraud the hotel restaurant at the time she gained possession of the food; and (2) the trial court did not find the essential element of specific intent beyond a reasonable doubt - that Defendant possessed the intent to cheat or defraud the hotel restaurant at the time she obtained the food.

Jefferson v. Commonwealth

Docket: 180993

Opinion Date: April 9, 2020

Judge: Per Curiam

Areas of Law: Criminal Law

The Supreme Court affirmed the judgment of the court of appeals dismissing as untimely Defendant's appeal of his convictions, holding that Defendant's immediate appeal was untimely. Defendant was convicted of abduction and assault and battery of a family member. Because the original sentencing order contained a scrivener's error the court entered an amended order adding handwritten notations on the first and last pages. Defendant appealed. The court of appeals dismissed the appeal as untimely, noting that the original order was the final appealable order and that the amended order was entered to correct a scrivener's error. Defendant appealed, arguing that the court of appeals erred in holding that the amended order was not the final order for purposes of noting his appeal. The Supreme Court affirmed, holding that the original order, and not the amended order, was the final appealable order in this case and that, therefore, Defendant's appeal was untimely.

Lambert v. Commonwealth

Docket: 190439

Opinion Date: April 9, 2020

Judge: Charles S. Russell

Areas of Law: Criminal Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for aggravated involuntary manslaughter and driving while intoxicated, holding that the Commonwealth presented evidence sufficient to support jury verdicts finding that Defendant had, prior to the accident, self-administered intoxicants that impaired his ability to drive safely. At the close of the Commonwealth's evidence, Defendant moved to strike it on the ground that the Commonwealth had failed to prove beyond a reasonable doubt that the drugs in his blood were self-administered. The trial court denied the motion, and the jury found Defendant guilty. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant's assignments of error relating to the question of whether the drugs found in his blood had been self-administered were without merit.

Curtis v. Highfill

Docket: 190117

Opinion Date: April 9, 2020

Judge: Chafin

Areas of Law: Medical Malpractice, Personal Injury

In this wrongful death case, the Supreme Court reversed the decision of the circuit court striking the evidence supporting a claim for punitive damages against Defendant, a physician who repeatedly prescribed narcotic pain medication to a patient, holding that, under the circumstances of this case, the circuit court erred by granting Defendant's motion to strike. The patient in this case died from an accidental overdose of oxycodone, alcohol, and prescription medications. Plaintiff, the administrator of the decedent's estate, filed a wrongful death action against Defendant. In addition to damages permitted in wrongful death actions the administrator requested an award of punitive damages. Defendant conceded that he breached the applicable standard of care with respect to his care and treatment of the decedent but moved to strike the punitive damages claim. The circuit court granted the motion to strike. At issue was whether a jury could have concluded that Defendant's actions constituted a "willful and wanton" disregard for the decedent's health and safety. The Supreme Court reversed, holding that, under the specific circumstances of this case, the administrator's punitive damages claim should have been submitted to the jury.