Ronald Villarroel v. Railing Systems, LLC

CourtCourt of Appeals of Virginia
DecidedFebruary 3, 2026
Docket1572244
StatusUnpublished

This text of Ronald Villarroel v. Railing Systems, LLC (Ronald Villarroel v. Railing Systems, 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
Ronald Villarroel v. Railing Systems, LLC, (Va. Ct. App. 2026).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Beales, Causey and White UNPUBLISHED

Argued by videoconference

RONALD VILLARROEL MEMORANDUM OPINION* BY v. Record No. 1572-24-4 JUDGE KIMBERLEY SLAYTON WHITE FEBRUARY 3, 2026 RAILING SYSTEMS, LLC

FROM THE CIRCUIT COURT OF ARLINGTON COUNTY Daniel S. Fiore, II, Judge

Tara L. Umbrino (Jennifer Porter; TLT Legal Services, PLLC; Jennifer Porter Law, PLLC, on briefs), for appellant.

Nicholas J. Phillips (Thomas, Thomas & Hafer, LLP, on brief), for appellee.

Ronald Villarroel appeals the circuit court’s judgment to sustain Railing Systems, LLC’s

(Railing Systems) plea in bar to his personal injury complaint. The circuit court determined that

the Workers’ Compensation Act (Act), Code §§ 65.2-300 through -307, precluded Villarroel’s

claim because Railing Systems and Villarroel were statutory co-employees of third-party

defendants BCN Design Build, LLC and BCN Enterprises, LLC (collectively BCN).1 Finding

no error, we affirm.

BACKGROUND

Villarroel worked at a residential construction project in Arlington in December 2021.

While working, he stepped on a window well egress grate and sustained serious injuries.

* This opinion is not designated for publication. See Code § 17.1-413(A). 1 BCN Enterprises, LLC oversees construction of projects, and BCN Design Build, LLC is a licensed general contractor. According to Villarroel, the grate gave way, causing him to fall down the window well.

Villarroel sued Railing Systems, arguing that it created a dangerous condition by failing to

properly install the grate.2 Villarroel’s complaint alleged four counts: (1) creation of a dangerous

condition; (2) failure to maintain; (3) failure to warn; and (4) negligent construction.

Railing Systems moved to file a third-party complaint for indemnification and

contribution against BCN. Over Villarroel’s objection, the circuit court granted the motion.

According to the third-party complaint, BCN provided installation instructions for the grate;

Railing Systems fabricated and installed the grate as specified and required by BCN; BCN

oversaw and controlled the construction project and construction safety; and BCN hired

Villarroel’s company and directed Villarroel’s work.

Railing Systems then filed a plea in bar, contending that Railing Systems and Villarroel

were both statutory employees of BCN under the Act, Code §§ 65.2-300 through -307. At the

plea in bar hearing, testimony indicated that BCN was the general contractor for the construction

project, and BCN’s contract required it to install the grate and complete the punchout work.

BCN subcontracted with Railing Systems to install the grate. BCN subcontracted with

Villarroel’s employer, Pristine Home Services (Pristine), to complete the punchout work, and

Villarroel performed Pristine’s work. Punchout work included details like installing doorknobs or

shower rods and applying touchup paint. BCN paid both Railing Systems and Pristine to work on

the project.

Railing Systems’ managing member and corporate designee, Mary Skelley, testified that

she field-measured the window-well opening for the grate, which had a ladder and a hatch door.

2 Villarroel had already “filed a suit against BCN in Richmond City Circuit Court.” However, based on the record, the case was dismissed with prejudice “upon agreement of the parties.” There is nothing in the record indicating any further action by Villarroel against BCN directly. -2- Then Railing Systems ordered the raw materials, cut them to the measurements taken, welded

them together, and primed them with a rustproof coating. As a non-expert witness, Skelley

testified that cutting and welding required specialized equipment and skills that she thought were

generally outside the skill set of an average general contractor.3 She added that Railing Systems

installed the grate at the property by drilling holes to install mounting brackets for the ladder,

bolting the brackets to the foundation or wall, bolting shelf angles, and mounting the grate on the

shelf angle.

From the evidence at the plea in bar hearing, the circuit court found among other things

that: (a) BCN contracted to build a residential dwelling at the property; (b) BCN engaged various

subcontractors to perform its contractual obligations, and BCN did not maintain employees to

perform the construction; (c) BCN subcontracted with Pristine, and Pristine performed BCN’s

trade; (d) Pristine employed Villarroel, who performed Pristine’s trade; (e) BCN subcontracted

with Railing Systems to fabricate and install the grate; (f) Railing Systems fabricated and

installed the grate “based on its own pre-inspection of the window well area”; and (g) Villarroel

fell through the grate’s window well while he worked. The circuit court found that Railing

Systems was “not a delivery service of material”; rather, it installed the grate. Railing Systems’

installation of the grate was necessary to fulfill BCN’s contractual obligation, and it therefore

constituted the trade, business, or occupation of BCN.

The circuit court considered Skelley’s lay testimony that welding was outside the skill set

of an average general contractor to be only “an opinion” without authority or expert support.

The circuit court found Skelley’s testimony unconvincing and unsupported by authority. The

circuit court stated: “There’s nothing that says a general contractor can’t perform welding.

3 Asked whether “for the average general contractor, the ironwork and welding work that you described for the Court is outside of the skill set of a general contractor,” Skelley answered, “Generally, yes.” -3- There’s no statutory provision. There’s no ordinance against it. The—you know, this is a

burden that the plaintiff assumed. And this Court is not persuaded.”

The circuit court held that the Act applied because Villarroel and Railing Systems were

statutory co-employees, and BCN was the statutory employer. Finding that the Act provided the

exclusive remedy for Villarroel’s claim, the circuit court sustained the plea in bar and dismissed

the complaint with prejudice. Villarroel appeals, arguing that the circuit court misapplied the

Act, misapplied the burden of proof, and disregarded Skelley’s testimony.

ANALYSIS

When an appellate court reviews a ruling on a plea in bar on which the parties have

presented evidence “ore tenus, the circuit court’s factual findings ‘are accorded the weight of a jury

finding and will not be disturbed on appeal unless they are plainly wrong or without evidentiary

support.’” Cornell v. Benedict, 301 Va. 342, 349 (2022) (quoting Massenburg v. City of Petersburg,

298 Va. 212, 216 (2019)). To the extent the review rests on legal questions, including statutory

construction, we review de novo. Id.

There are two main ways in which a court can establish evidentiary support for a plea in bar:

“based on a discrete body of facts identified by the parties through their pleadings, or developed

through the presentation of evidence supporting or opposing the plea.” Hawthorne v. VanMarter,

279 Va. 566, 577 (2010). On the latter, “if the facts are disputed and no demand for a jury is made,

the ‘whole matter of law and fact’ may be decided by the court.” Ferguson Enters., Inc. v. F.H.

Furr Plumbing, Heating & Air Conditioning, Inc., 297 Va. 539, 549 (2019) (quoting Hawthorne,

279 Va. at 578).

To enable parties to present supporting evidence for a plea in bar, a trial court may hold an

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Napper v. ABM JANITORIAL SERVICES
726 S.E.2d 313 (Supreme Court of Virginia, 2012)
David White Crane Service v. Howell
714 S.E.2d 572 (Supreme Court of Virginia, 2011)
Elliott v. Com.
675 S.E.2d 178 (Supreme Court of Virginia, 2009)
Moorman v. Blackstock, Inc.
661 S.E.2d 404 (Supreme Court of Virginia, 2008)
Baker v. Poolservice Company
636 S.E.2d 360 (Supreme Court of Virginia, 2006)
Jones v. Commonwealth
591 S.E.2d 72 (Supreme Court of Virginia, 2004)
Beeton v. Beeton
559 S.E.2d 663 (Supreme Court of Virginia, 2002)
Bosley v. Shepherd
554 S.E.2d 77 (Supreme Court of Virginia, 2001)
Fowler v. International Cleaning Service, Inc.
537 S.E.2d 312 (Supreme Court of Virginia, 2000)
Princess Anne Builders, Inc. v. Faucette
554 S.E.2d 113 (Court of Appeals of Virginia, 2001)
Cinnamon v. International Business MacHines Corp.
384 S.E.2d 618 (Supreme Court of Virginia, 1989)
Cooke v. Skyline Swannanoa, Inc.
307 S.E.2d 246 (Supreme Court of Virginia, 1983)
Whalen v. Dean Steel Erection Co., Inc.
327 S.E.2d 102 (Supreme Court of Virginia, 1985)
Southeastern Tidewater Area Manpower Authority v. Coley
275 S.E.2d 589 (Supreme Court of Virginia, 1981)
Yarborough v. Commonwealth
234 S.E.2d 286 (Supreme Court of Virginia, 1977)
Hipp v. Sadler Materials Corp.
180 S.E.2d 501 (Supreme Court of Virginia, 1971)
Bassett Furniture Industries, Inc. v. McReynolds
224 S.E.2d 323 (Supreme Court of Virginia, 1976)
Bosher v. Jamerson
151 S.E.2d 375 (Supreme Court of Virginia, 1966)
Kole v. City of Chesapeake
439 S.E.2d 405 (Supreme Court of Virginia, 1994)
Carmody v. F. W. Woolworth Co.
361 S.E.2d 128 (Supreme Court of Virginia, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
Ronald Villarroel v. Railing Systems, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronald-villarroel-v-railing-systems-llc-vactapp-2026.