Jill Genders v. Rope Lane, LLC

CourtCourt of Appeals of Virginia
DecidedSeptember 16, 2025
Docket0137241
StatusUnpublished

This text of Jill Genders v. Rope Lane, LLC (Jill Genders v. Rope Lane, 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
Jill Genders v. Rope Lane, LLC, (Va. Ct. App. 2025).

Opinion

COURT OF APPEALS OF VIRGINIA UNPUBLISHED

Present: Judges Fulton, Ortiz and Lorish Argued at Norfolk, Virginia

JILL GENDERS MEMORANDUM OPINION* BY v. Record No. 0137-24-1 JUDGE LISA M. LORISH SEPTEMBER 16, 2025 ROPE LANE, LLC

FROM THE CIRCUIT COURT OF THE CITY OF VIRGINIA BEACH Steven C. Frucci, Judge1

Brandon L. Ballard (Elizabeth J. Davis; Legal Aid Society of Eastern Virginia, on brief), for appellant.

No brief or argument for appellee.

Jill Genders appeals from the circuit court’s order awarding judgment and possession to

Rope Lane, her former landlord, after Rope Lane filed an unlawful detainer. The crux of the case is

whether Rope Lane was allowed to give notice of termination of the lease through certified mail.

Genders argues that certified mail was not permitted under the Virginia Residential Landlord and

Tenant Act (VRLTA), so the court erred in finding that Rope Lane had satisfied the notice

requirement. We affirm the circuit court because Genders conceded that certified mail was

permissible under the terms of her lease with Rope Lane, waiving any argument to the contrary on

appeal, and nothing in the VRLTA prohibits the parties from agreeing to alternate forms of notice.

* This opinion is not designated for publication. See Code § 17.1-413(A). 1 Judge Westbrook J. Parker presided over the motion to require rent to be escrowed. Judge Steven C. Frucci presided over the unlawful detainer trial prior to his election to this Court. Because we reach this conclusion, we need not evaluate the court’s finding in the alternative that

Genders’s good faith defenses failed to satisfy the requirements of Code § 55.1-1242.

BACKGROUND

On August 17, 2020, Jill Genders signed a residential lease at 3809 Rope Lane in Virginia

Beach, Virginia with Rope Lane, LLC. The lease commenced on August 29, 2020, with a monthly

rent of $1,400. Either party was authorized to terminate the tenancy by “giving the other party

written notice at least Thirty (30) days before the end of such Term.” The lease provided that “[i]f

no such notice of termination is given, the . . . lease shall be extended for self-renewing terms of

month to month duration until either party gives notice to terminate . . . unless [the] Lease is

terminated in accordance with any other applicable provision of [the] Lease or Virginia law.” The

lease also provided that, “[a]ll notices shall be provided in writing and may be given by regular mail

or hand delivery, with the party giving notice retaining a certificate of mailing or delivery of the

notice as the case may be.”

In early 2023, Genders noticed physical defects in the home and contacted the city of

Virginia Beach about them in February 2023. In April, Genders filed a tenant’s assertion in the

General District Court of the City of Virginia Beach because the issues had not been resolved. She

paid her monthly rent into the court’s escrow account from April to July of 2023 while the assertion

was pending.2

On May 23, 2023, Rope Lane sent a “Notice to Quit” to Genders’s residence by certified

mail. The notice stated that her tenancy “is hereby terminated as of June 30, 2023” and that she

would be required to vacate by that date. The notice also clarified that it “is intended as a thirty . . .

2 Pursuant to Code § 55.1-1244(B)(2), the tenant making the assertion must show that she “has paid into court the amount of rent called for under the rental agreement, within five days of the date due under the rental agreement, unless or until such amount is modified by subsequent order of the court under this chapter.” -2 - day legal notice for purposes of recovering possession of the property . . . in accordance with the

[VRLTA §] 55-248.37.”3 But Genders was not home at the time the notice was delivered. As such,

USPS left a “Certified Mail Receipt” indicating that it attempted delivery of a piece of certified mail

and that she could pick it up at the post office. The note did not say who sent the certified mail or

what it contained. The envelope containing the notice was eventually marked as “unclaimed” and

“return[ed] to sender” on July 12, 2023.

Rope Lane filed an unlawful detainer action in the general district court in July 2023 based

on Genders’s failure to vacate the property after non-renewal and her alleged nonpayment of rent

from April through July of that year. On August 22, the district court heard both Genders’s tenant’s

assertion and Rope Lane’s unlawful detainer action. The court dismissed the tenant’s assertion and

ruled in favor of Rope Lane on the unlawful detainer, awarding Rope Lane possession of the

property and the amount of rent that had been held in escrow. Genders appealed to the circuit court.

On October 19, 2023, while Genders’s appeal was pending, Rope Lane filed a “complaint

for [an] unlawful detainer” in the circuit court on the grounds that Genders was “unlawfully

withholding possession,” seeking an order of possession and damages incurred “[a]s a result of

[Genders] holding over and failing to vacate the premises after the termination of the rental term.”

Rope Lane sought 150% of Genders’s monthly rent due from September to November 2023 in the

amount of $6,300, and attorney fees and court costs in the amount of $7,653.53. Genders did not

pay rent into escrow from September to December of 2023, the months during which the unlawful

detainer was pending in the circuit court.

On November 27, Genders appeared at trial and requested a continuance. The trial was

rescheduled for December 22. In response to Genders’s request for the continuance, and pursuant to

3 Code § 55-248.37 is the prior version of Code § 55.1-1253, which governs termination of periodic tenancies and holdover remedies. See 2013 Va. Acts ch. 563. -3 - Code § 55.1-1242, Rope Lane moved the circuit court to order Genders to pay $5,600 (four-months’

rent) into escrow, and to award Rope Lane possession of the premises if she failed to pay the

requisite amount within one week.

On December 15, 2023, the circuit court held a hearing on Rope Lane’s motion for rent to

be escrowed. At this hearing, Genders and Rope Lane only proffered evidence and did not call

witnesses. The court ordered Genders to pay $5,600 into escrow within one week of the order, by

noon on December 22. If she failed to pay, the court warned that it would “enter judgment” and an

order of possession in Rope Lane’s favor. Genders objected to the order “for the reasons stated at

the hearing on [December 15] and because requiring rent escrow after [she] asserted good faith

defenses expressly violates section 55.1-1242 of the Code of Virginia.”

On December 18, Genders filed a motion to reconsider the court’s order requiring her to pay

four months’ rent into escrow because she had asserted “good faith defense[s]” within the meaning

of Code § 55.1-1242. Specifically, Genders asserted that (1) she was never served with a lease

termination notice and (2) “any act to terminate [her] tenancy was a retaliatory act” under

§ 55.1-1258. On notice, Genders attached a picture of the envelope, containing the notice to quit,

that stated that the notice sent by certified mail went unclaimed, as well as an image of the USPS

tracking information showing that the envelope had been “return[ed] to sender.”4 Genders asserted

that, to terminate a month-to-month tenancy under Code § 55.1-1253(A), a landlord must serve a

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