Harry Warren v. Aikey's Home Improvements, LLC

CourtCourt of Appeals of Virginia
DecidedAugust 26, 2025
Docket1179242
StatusUnpublished

This text of Harry Warren v. Aikey's Home Improvements, LLC (Harry Warren v. Aikey's Home Improvements, LLC) 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
Harry Warren v. Aikey's Home Improvements, LLC, (Va. Ct. App. 2025).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges O’Brien, Fulton and White UNPUBLISHED

Argued by videoconference

HARRY WARREN MEMORANDUM OPINION* BY v. Record No. 1179-24-2 JUDGE JUNIUS P. FULTON, III AUGUST 26. 2025 AIKEY’S HOME IMPROVEMENTS, LLC, ET AL.

FROM THE CIRCUIT COURT OF CHESTERFIELD COUNTY David E. Johnson, Judge

Jason M. Hart (The Joel Bieber Law Firm, on briefs), for appellant.

Peter S. Askin (John P. O’Herron; ThompsonMcMullan, PC, on brief), for appellee Aikey’s Home Improvements, LLC.

R. Jamie Sinnott, IV (Sinnott, Nuckols & Logan, P.C., on brief), for appellee Worley’s Masonry, LLC.

Harry Warren appeals the trial court’s orders dismissing his suit against Aikey’s Home

Improvements, LLC (Aikey’s) and Worley’s Masonry, LLC (Worley’s). Warren argues that his

complaint pleaded negligence against Aikey’s and that his claims are not barred under the

Virginia Workers’ Compensation Act (the Act). For the reasons stated below, we find the trial

court’s July 9, 2024, order to be void for lack of jurisdiction and dismiss this appeal for lack of

jurisdiction.

* This opinion is not designated for publication. See Code § 17.1-413(A). BACKGROUND1

Aikey’s was contracted to build an addition to a house. Aikey’s hired Worley’s to dig

trenches for the foundation. With Aikey’s knowledge and assent, Worley’s dug holes

approximately two to three feet deep. Worley’s did not provide any warnings about the holes,

and they filled with water and debris such that they appeared to be puddles. Aikey’s hired

Warren’s Home Repair and Demo, LLC (Home Repair) to install sill plates to frame the house.

When Warren, the owner of Home Repair, arrived on site to begin the installation, he mistook

one of the holes for a puddle and stepped into it, causing him serious and permanent injuries.

Warren sued Aikey’s and Worley’s for negligence. Aikey’s demurred, arguing that it

was not responsible for Worley’s actions. Warren argued that he was not suing Aikey’s under a

theory of vicarious liability, but premises liability for failure to warn of or ameliorate the danger.

The trial court sustained Aikey’s demurrer and granted Warren leave to file an amended

complaint clarifying his claim.

In his amended complaint, Warren alleged that Aikey’s had actual knowledge of the

holes and their condition. He also stated that Aikey’s and Worley’s had breached their duties of

ordinary care to Warren, an invitee, by failing to warn him about the holes or make them less

dangerous. Aikey’s again demurred, arguing that Warren had not alleged that Worley’s was

anything but a subcontractor, and it was not vicariously liable for Worley’s actions. At a

hearing, the trial court found that no exception applied to the general rule that general contractors

are not responsible for the actions of subcontractors. Accordingly, on February 28, 2024, it

sustained Aikey’s demurrer and dismissed it from Warren’s suit.

1 When reviewing a trial court’s judgment sustaining a demurrer, “we accept as true all factual allegations expressly pleaded in the complaint and interpret those allegations in the light most favorable to the plaintiff.” A.H. v. Church of God in Christ, Inc., 297 Va. 604, 613 (2019). “Our recitation of the facts, of course, restates only factual allegations that, even if plausibly pleaded, are as yet wholly untested by the adversarial process.” Id. at 614. -2- For its part, Worley’s filed a plea in bar arguing that the Act deprived the trial court of

subject matter jurisdiction over Warren’s claim. Worley’s asserted that Home Repair was its

statutory co-employee under the Act. At a hearing, Kirk Aikey testified that Aikey’s was tasked

with demolishing a porch and fence and building an addition on the owner’s property. Aikey’s

hired Home Repair to do the demolition work and framing of the addition. Warren did not

dispute these assertions. Warren testified that he had not elected to be covered under Home

Repair’s workers’ compensation insurance plan.

In a letter opinion, the trial court found that Warren likely fulfilled a managerial position

within Home Repair, so he was an employee under the Act. The trial court also noted that

regardless of whether he was a manager or employee of Home Repair, Warren was presumed to

have accepted the provisions of the Act. Thus, on February 13, 2024, the trial court granted

Worley’s plea in bar and dismissed Warren’s suit entirely.

On March 13, 2024, Warren petitioned the trial court to reconsider, arguing that he was

neither a manager nor an employee under the Act, so the Act did not apply. At the conclusion of

a hearing on May 21, 2024, the trial court announced that it intended to enter the dismissal order

but took Warren’s motion under advisement. On May 21, 2024, the trial court entered the final

dismissal order, placing the case “among the ended causes.” On June 28, 2024, the trial court

issued a letter opinion, affirming its previous ruling on alternate grounds. The trial court found

that because Warren was the sole member of Home Repair, he was an employee covered by the

Act. The trial court added that its previous ruling remained in effect.

On July 9, 2024, Warren moved the trial court to vacate the May order under Code

§ 8.01-428(C), arguing that, despite his diligence, he was unaware that the order had been

entered and the time to appeal had passed. On July 9, 2024, the same day that Warren filed his

-3- motion, the trial court vacated the May final order, granted Worley’s plea in bar, and dismissed

the complaint. Warren filed his notice of appeal on July 15, 2024.

ANALYSIS

“‘No appeal shall be allowed unless, within 30 days after entry of final judgment . . .

counsel files with the clerk of the trial court a notice of appeal’ . . . . If a timely notice is not

filed . . . the appeal must be dismissed for lack of jurisdiction.” Sanchez v. Commonwealth, 14

Va. App. 256, 258-59 (1992) (quoting Rule 5A:6(a)). Pending motions to reconsider do not toll

the 30-day deadline for a party to file a notice of appeal. Wells v. Shenandoah Valley Dep’t of

Soc. Servs., 56 Va. App. 208, 213 (2010). One of the few exceptions to this rule is in Code

§ 8.01-428(C), which allows a party who was unaware of the final order to seek a remedy. To

provide relief under Code § 8.01-428(C), the trial court must make certain findings of fact.

Specifically, the trial court must determine that the lack of notice (1) did not result from a failure

to exercise due diligence on the part of that party and (2) denied the party an opportunity to

pursue post-trial relief in the circuit court. See Rose v. Jacques, 268 Va. 137, 147 (2004) (“[O]ur

inquiry is whether the trial court made the necessary findings under the statute and whether those

findings are supported by the record.”). If the trial court makes such findings of fact within 60

days of the final order, the trial court may vacate the final order or grant leave to the party to file

an appeal. Code § 8.01-428(C). Finally, the trial court cannot revisit a final order under Code

§ 8.01-428(C) unless the trial court finds the requirements under the Code in such a manner that

this Court may review them.

The trial court issued its final order on May 21, 2024. Warren did not file a notice of

appeal within the next 30 days. However, on July 9, 2024, he filed a motion under Code

§ 8.01-428(C), arguing that he had been unaware of the court’s final order and thus should be

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Related

Rose v. Jaques
597 S.E.2d 64 (Supreme Court of Virginia, 2004)
Wells v. Shenandoah Valley Department of Social Services
692 S.E.2d 286 (Court of Appeals of Virginia, 2010)
Sanchez v. Commonwealth
14 Va. App. 256 (Court of Appeals of Virginia, 1992)

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