Anthony Burchard v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedJanuary 28, 2025
Docket1432232
StatusUnpublished

This text of Anthony Burchard v. Commonwealth of Virginia (Anthony Burchard v. Commonwealth of Virginia) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anthony Burchard v. Commonwealth of Virginia, (Va. Ct. App. 2025).

Opinion

COURT OF APPEALS OF VIRGINIA UNPUBLISHED

Present: Judges O’Brien, Malveaux and Raphael Argued at Richmond, Virginia

ANTHONY BURCHARD, ET AL. MEMORANDUM OPINION* BY v. Record No. 1432-23-2 JUDGE MARY GRACE O’BRIEN JANUARY 28, 2025 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF LOUISA COUNTY Timothy K. Sanner, Judge

Christopher M. Okay for appellants.

Erin R. McNeill, Assistant Attorney General (Jason S. Miyares, Attorney General; Charles H. Slemp, III, Chief Deputy Attorney General; Steven G. Popps, Deputy Attorney General; Jacqueline C. Hedblom, Senior Assistant Attorney General; Christopher P. Bernhardt, Assistant Attorney General, on brief), for appellee.

Anthony and Renee Burchard appeal the dismissal of their Virginia Tort Claims Act

(VTCA) action against the Commonwealth that sought damages arising from an improperly sited

well on their property. The court dismissed the action as time-barred under the VTCA because the

Burchards did not submit a notice of claim within a year from when the well was drilled.

The Burchards’ eight assignments of error fall into three categories. First, they argue the

court erred in finding that their cause of action accrued when the well was drilled, rather than when

they began suffering economic losses later.

Second, the Burchards contend the court erred by not tolling the VTCA’s one-year

limitations period under Code § 8.01-229(D), because the evidence showed that the Commonwealth

used “direct or indirect means to obstruct the filing” of this action.

* This opinion is not designated for publication. See Code § 17.1-413(A). Finally, they challenge the court’s evidentiary decision to exclude a state agency’s “manual”

for implementing regulations related to private wells. Finding no error, we affirm.

BACKGROUND

The facts are largely undisputed. On August 12, 2016, an inspector from the Louisa County

Health Department visited the Burchards’ property to identify a suitable location for a new well.

The inspector issued a private well construction permit that attached a drawing of the location he

approved; he also marked the location with four wooden stakes.

The permit stated that it “is null and void . . . if conditions are changed from those shown on

the attached construction drawings and specifications.” The permit also provided that the

“landowner is responsible at all times for complying with all applicable local, state, and federal laws

and regulations, and for ensuring that the water well is properly located on the landowner’s property

and in the approved area.”

The permit required the Burchards, as the landowners, to take certain steps after drilling the

well but before putting it into operation:

Your private well must be inspected by a representative of the local health department. Your private well may not be placed into operation until you have obtained a Record of Inspection (ROI) from the Louisa County Health Department.

Before you can obtain your ROI, you must provide the Health Department with a complete Water Well Completion Statement . . . from your well driller and a record of a satisfactory bacteriological sample result.

Although the permit’s attached construction drawing depicted the proposed well’s location

as 57 feet from a septic drainfield on the Burchards’ property, that drawing did not reflect the actual

location of the drainfield. In fact, the proposed well location was within the septic drainfield. As a

result, the Burchards’ contractor drilled a well within the drainfield on August 18, 2016 in violation

of Virginia Department of Health (VDH) administrative agency regulations. See, e.g., 12 VAC

-2- 5-630-380(A); Table 3.1 (requiring minimum separation of 50 feet between certain private wells

and a septic drainfield).

The Burchards did not obtain a bacteriological sample of the water from the well as required

by their permit. With no bacteriological sample of the well water, the VDH could not conduct its

final inspection and issue a record of inspection. The Burchards thus did not obtain a record of

inspection before putting their well into service, violating the permit’s terms. The Burchards started

to draw water from the well in September 2016.

VDH had no contact with the Burchards for over a year after issuing the permit.

In February 2018, when attempting to sell their property, the Burchards obtained a

third-party inspection of the septic system and learned that their well had been improperly located.

The inspector’s report stated that the well “appear[ed] to be located in the existing [septic] drainfield

and [was] within 33’ of the existing septic tank” and therefore did “not meet the current

regulations.” The report advised “ceasing all water consumption from this well until this issue with

the drainfield can be resolved.”

The Burchards submitted a notice of claim to the Commonwealth’s Division of Risk

Management (DRM) on June 26, 2018. In September 2018, a DRM representative informed the

Burchards that it was reviewing their claim. In October 2018, the Burchards rejected an offer from

DRM and stated that they would pursue their matter in court.

The Burchards brought a VTCA action on December 20, 2019, alleging damages resulting

from negligence by the Commonwealth’s VDH employee in inspecting the property and siting the

well on or around August 12, 2016. The Burchards also sued their drilling contractor for breach of

contract and negligence.

Significantly, the complaint alleged that VDH employees had inspected the well after it was

drilled and had issued a record of inspection before the Burchards began using the well. The

-3- Commonwealth filed a plea in bar asserting that the claims were time-barred under the VTCA. At a

hearing, the court found that the Burchards’ cause of action accrued in August 2016. However, the

Burchards argued that the VTCA limitations period should be tolled pursuant to Code

§ 8.01-229(D) because the VDH allegedly inspected the well after it was drilled and authorized its

use, reflecting an affirmative misrepresentation that obstructed the filing of the action. The court

therefore denied the Commonwealth’s plea in bar so that the parties could exchange discovery on

the issue of whether the Commonwealth used “direct or indirect means to obstruct the filing of the

action” that would toll the VTCA limitations period pursuant to Code § 8.01-229(D).

The Commonwealth subsequently renewed its plea of the statute of limitations, arguing

there was no basis to toll the statute. Discovery revealed that, contrary to the complaint, the

Burchards had not obtained the record of inspection before using their well and that VDH had not

communicated with them in either 2016 or 2017 after issuing the permit.

At a hearing on the Commonwealth’s renewed plea, the court heard argument and received

evidence in the form of exhibits attached to the pleadings. When the Burchards attempted to rely on

the VDH’s manual for implementing private well regulations, the court sustained the

Commonwealth’s objection because the agency’s internal guidelines were not admissible to

establish the standard of care.

Consistent with its prior ruling, the court determined that the Burchards’ cause of action

against the Commonwealth accrued “on or about August 19, 2016 when the well at issue in this

litigation was drilled.”1 The court found that the Burchards submitted their notice of claim on June

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