Peterson v. Commonwealth

80 Va. Cir. 21, 2010 Va. Cir. LEXIS 7
CourtMontgomery County Circuit Court
DecidedJanuary 12, 2010
DocketCase No. CL09-005525; Case No. CL09-005526
StatusPublished
Cited by2 cases

This text of 80 Va. Cir. 21 (Peterson v. Commonwealth) is published on Counsel Stack Legal Research, covering Montgomery County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peterson v. Commonwealth, 80 Va. Cir. 21, 2010 Va. Cir. LEXIS 7 (Va. Super. Ct. 2010).

Opinion

By Judge William N. Alexander, II

Since the complaints filed by plaintiffs are essentially the same and, likewise, since the Demurrer and Special Pleas of Sovereign Immunity are essentially the same for each group of the defendants, I will address the demurrers and special pleas of all parties in one letter.

I have received copies of the Second Amended Complaints as well as the objections to the filing of the amended complaints. I have not read these complaints and will take no action on them until after a hearing has been held.

All claims against Christopher Flynn, Sandra Ward, Wendell R. Flinchum, James Thomas Brown, and Kay K. Heidbreder have been dismissed by an order of nonsuit entered on the 8th day of January 2010.

I. Plea of Sovereign Immunity of the Commonwealth of Virginia and of the Individual Defendants, Charles W. Steger, James A. Hyatt, Mark G. McNamee, David R. Ford, Lawrence G. Hincker, and Ralph M. Byers (Virginia Tech Officials)

Defendants, the Virginia Tech officials, maintain the claims of the First Amended Complaint must be dismissed against them because as high-ranking governmental officials they are protected by absolute immunity. The initial question confronting this court is whether any, or all, of these officials are entitled to absolute immunity by virtue of their [23]*23positions at Virginia Tech, are entitled to immunity from simple negligence claims or entitled to no immunity at all.

The doctrine of sovereign immunity is “alive and well” in Virginia. Messina v. Burden, 228 Va. 301, 307 (1984). As a general rule, the Commonwealth is immune both from actions at law for damages and from suits in equity to restrain governmental action or to compel such action. Hinchey v. Ogden, 226 Va. 234, 239 (1983). Only the legislature acting in its policy-making capacity can abrogate the Commonwealth’s immunity. Commonwealth v. Luzik, 259 Va. 198, 206 (2000). A waiver of sovereign immunity will not be implied from general statutory language but must be explicitly and expressly stated in the statute. Hinchey, 226 Va. at p. 241. The Virginia Tort Claims Act does provide a limited waiver of the state’s immunity from tort claims but it does not waive sovereign immunity as to the Commonwealth’s employees. The Act provides that:

Notwithstanding any provision hereof, the individual immunity of judges, the Attorney General, attorneys for the Commonwealth, and other public officers, their agents and employees from tort claims for damage is hereby preserved to the extent and degree that such persons presently are immunized.

Va. Code Ann. § 8.01-195.3

In James v. Jane, 221 Va. 43, 53 (1980), the Supreme Court in its discussion of sovereign immunity recognized that valid reasons still exist for state employee immunity, but also said the argument for immunity “does not have the same strength it had in past years” because of the intrusion of government into areas formerly private and because of the tremendous increase in the number of state employees. The Court found “no justification for treating a present day government employee as absolutely immune from tort liability, just as if he were an employee of an eighteenth century sovereign.” The Court noted that:

It is proper that a distinction be made between the state, whose immunity is absolute unless waived, and the employees and officials of the state, whose immunity is qualified, depending upon the function they perform and the manner of performance. Certain state officials and state employees must of necessity enjoy immunity in the performance of their duties. These officers are inclusive of, [24]*24but not limited to, the Governor, state officials and judges. They are required by the Constitution and by general law to exercise broad discretionary powers, often involving both the determination and implementation of state policy.

James, p. 53. Later, in Messina, the Court stated:

There is very little debate regarding the extension of the doctrine of sovereign immunity to those who operate at the highest levels of the three branches of government. Governors, judges, members of state and local legislative bodies, and other high level governmental officials have generally been accorded absolute immunity. General agreement breaks down, however, the farther one moves away from the highest levels of government.

Messina, supra, at p. 309 (citations omitted).

The Court in Alliance to Save the Mataponi, 270 Va. 423 (2005), concluded the Commonwealth was immune. The Court also held that the Executive Secretary of the Water Control Board, occupied a high-level governmental position and, while acting in his official capacity, was entitled to absolute immunity. The Court said:

As we explained in Messina v. Burden, the purposes of the doctrine of sovereign immunity cannot be achieved by affording protection solely to the sovereign itself, because the Commonwealth can act only through its individual employees. If every government employee were subject to suit, the Commonwealth would be as hampered in its operations as if it were the actual subject of the suit. Thus high-level governmental officials generally have been afforded absolute immunity.

Alliance, p. 455 (citation omitted).

It seems safe to conclude that high-level governmental officials are absolutely immune from actions at law for damages and suits in equity to compel or restrain governmental action while acting in their official capacities. If an official is a high-level governmental official, he or she is absolutely immune and no other factors like those set out in James, supra, [25]*25at pp. 53-54, and further discussed in Messina, supra, at pp. 313-14, need be considered.

What is not so clear is what defines a high ranking governmental official. The cases give little guidance to aid in the analytical process. Those persons, like Mr. Burnley, the Water Control Board’s Executive Secretary, who are appointed by the Governor or the General Assembly, whose duties and responsibilities are described by statute, and whose duties involve application of state law and policies statewide are high-level governmental officials protected by absolute immunity.

The Virginia Tech officials are not appointed by the Governor or the legislature. The Governor, appoints the Board of Visitors, who at all times is under the control of the General Assembly. The Board of Visitors appoints the president and vice-president and the other officials as necessary.

While the Board is required by statute, Va. Code Ann. § 23-1262, to appoint a president, neither the duties of the president or the vice-president are set by statute. In contrast, the Board of Visitors’ duties, responsibilities, and powers are set by statute. The Board is charged with the care, preservation, and improvement of the university’s property, the control of its property, the protection and safety of its students, and the government and discipline of its students. The Board is to govern the university by making such regulations as are necessary. The Board appoints the university’s professors, sets their salaries, and prescribes the duties of each. The Board is charged with administering the Virginia Cooperative Extension and Agricultural Experiment Station Division, a division of the university.

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93 Va. Cir. 459 (Hampton County Circuit Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
80 Va. Cir. 21, 2010 Va. Cir. LEXIS 7, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peterson-v-commonwealth-vaccmontgomery-2010.