Norfolk Community Services Board v. Berardi

84 Va. Cir. 310, 2012 WL 7865639, 2012 Va. Cir. LEXIS 25
CourtNorfolk County Circuit Court
DecidedFebruary 15, 2012
DocketCase No. (Civil) CL11-2968
StatusPublished

This text of 84 Va. Cir. 310 (Norfolk Community Services Board v. Berardi) is published on Counsel Stack Legal Research, covering Norfolk County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Norfolk Community Services Board v. Berardi, 84 Va. Cir. 310, 2012 WL 7865639, 2012 Va. Cir. LEXIS 25 (Va. Super. Ct. 2012).

Opinion

By Judge Everett A. Martin, Jr.

This matter came before the court on February 13,2012, on the amended complaint and demurrers, pleas in bar, and motions filed by the defendants.

The plaintiff, the “CSB,” complains that Jill D. McGlone, a former employee, improperly received a salary and other benefits from the time of her suspension on April 14, 1998, until May 15, 2010. (Nos. 14, 25.) (The numbers in parentheses refer to paragraphs of the amended complaint.) The [311]*311CSB seeks to recover the value of the salary and benefits from McGlone and these four other defendants.

Linda Berardi was the CSB’s Human Resource Officer from 2002 until after McGlone’s termination. (Nos. 5, 50.) Her duties included compensation, classification, “payroll enrollment and transactions,” and benefits administration. (No. 35.)

Anthony Crisp was the Director of Clinical Services for the CSB, and he suspended McGlone. (Nos. 4 and 14.) His duties included the coordination of substance abuse services, employee performance reviews, and disciplinary actions. (No. 71.)

Brenda Wise was the Director ofAdministration for the CSB. (No. 3.)Her duties included personnel and financial management and the supervision of Berardi. (No. 104.)

George Pratt was the Executive Director of the CSB from 1996 until March 31, 2008. (No. 6.) He was responsible for the removal of any employee, the implementation of the CSB’s policies, and the administration of the budget. (No. 143.)

The CSB has sued McGlone for unjust enrichment (Count One), Berardi, Crisp, Wise, and Pratt for fraud (Counts Two, Three, Four, and Six) and negligence (Counts Seven, Eight, Nine, and Ten), and Pratt for breach of contract (Count Five).

Unjust Enrichment

An action for unjust enrichment lies when one has money of another that he has no right to retain. Robertson v. Robertson, 137 Va. 378, 119 S.E. 140 (1923). McGlone does not contest that the CSB has adequately pleaded this claim, but she has filed a plea in bar of the statute of limitations claiming the CSB may not recover any amounts paid to her before April 12, 2008. The CSB has filed an objection to the Court’s hearing the plea in bar, and it demands that the facts be determined by a jury.

If there are disputed facts that must be resolved to allow the Court to rule on a plea in bar, either party is entitled to have a jury determine those facts. Hawthorne v. VanMarter, 279 Va. 566, 692 S.E.2d 226 (2010). Although McGlone’s pleading is styled as a special plea in bar, it is not actually so as it does not bar the CSB from recovering, but, if granted, would greatly reduce any recovery. Nonetheless, the Supreme Court has noted that a party may demand a jury trial of any issue in an action at law. Bethel Investment Co. v. City of Hampton, 272 Va. 765, 769, 636 S.E.2d 466, 470 (2006); Code of Virginia § 8.01-336(B). Thus, it would appear the CSB should have a jury trial on McGlone’s plea if there are disputed facts.

But are there disputed facts on her plea? I find there are not. The issue here is not when the limitations period began to run, as in an action for [312]*312fraud. On a claim of unjust enrichment, the limitations period runs from the date money or property is given to the defendant.

In Belcher v. Kirkwood, 238 Va. 430, 383 S.E.2d 729 (1989), the plaintiff gave money to the defendant on divers dates. When the defendant did not repay the money, the plaintiff sued. The defendant pleaded the statute of limitations. Even though the case had been transferred to equity, the Supreme Court held the claims were “cognizable at law” and the three year statute of limitations for oral contracts applied to claims for unjust enrichment and barred recovery for monies paid more than three years before the suit was filed. 238 Va. at 432-33, 383 S.E.2d at 730-31. As in Belcher, the claim here is for money damages, the traditional legal remedy, and Va. Code § 8.01-230 does not apply as the relief sought is not solely equitable.

The CSB claims the tolling provision of Va. Code § 8.01~229(D) allows it to recover from McGlone the damages it incurred more than three years before it filed suit. That sub-section provides, as applicable:

When the filing of an action is obstructed by a defendant’s .. . using any other direct or indirect means to obstruct the filing of an action, then the time that such obstruction has continued shall not be counted as any part of the period within which the action must be brought.

The CSB conceded at argument that McGlone took no action to obstruct the filing of this action, but it claims that other defendants did. The CSB offered no authority that would apply this sub-section to one defendant when another defendant acted to obstruct the filing of an action, and, in the absence of such authority or, perhaps, a relationship that would make the non-obstructing defendant vicariously liable for the acts of the obstructing defendant, I decline to so construe the statute. See former Va. Code § 8-33; Culpeper Nat'l Bank v. Tidewater Improv. Co., 119 Va. 73, 83-83, 89 S.E. 118, 121 (1916).

I find the CSB may recover from McGlone for unjust enrichment for salary paid and benefits bestowed within the three years before the suit was filed, that is, since April 12, 2008. The CSB’s claim for salary paid and benefits bestowed before that date is time barred.

Fraud and Negligence

The CSB sues Berardi, Crisp, Wise, and Pratt for actual or constructive fraud and negligence or gross negligence. Actual fraud is a false representation of a material fact made intentionally and knowingly with the intent to mislead, which representation is relied upon by the plaintiff and causes him damage. Constructive fraud differs in that the representation need only be made innocently or negligently and there need not be an intent [313]*313to mislead. Evaluation Research Corp. v. Alequin, 247 Va. 143, 439 S.E.2d 387 (1994).

The defendants demur contending these claims are barred by what is known as the source of duty rule. This rule is designed to maintain the separation of the law of contracts from that of torts. The law of contracts exists to protect the expectations of parties to a contract. The damages a plaintiff may recover in a contract action are usually rather limited. Because of the limited damages that may be recovered in a contract action, lawyers for plaintiffs often try to sue in tort, where the damages can be much higher. The primary purpose of the law of torts is the protection of persons and property from injury, and it affords a remedy only for violations of common law and statutory duties involving the safety of persons and property that are imposed to protect the broad interests of society. Filak v. George, 267 Va. 612, 594 S.E.2d 610 (2004).

A second reason a lawyer for a plaintiff may seek to sue in tort (especially for fraud) is the statute of limitations.

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Bluebook (online)
84 Va. Cir. 310, 2012 WL 7865639, 2012 Va. Cir. LEXIS 25, Counsel Stack Legal Research, https://law.counselstack.com/opinion/norfolk-community-services-board-v-berardi-vaccnorfolk-2012.