Shenk v. Spangler

46 Va. Cir. 277, 1998 Va. Cir. LEXIS 189
CourtRockingham County Circuit Court
DecidedJuly 31, 1998
DocketCase No. (Law) 10925; Case No. (Law) 10926
StatusPublished
Cited by1 cases

This text of 46 Va. Cir. 277 (Shenk v. Spangler) is published on Counsel Stack Legal Research, covering Rockingham County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shenk v. Spangler, 46 Va. Cir. 277, 1998 Va. Cir. LEXIS 189 (Va. Super. Ct. 1998).

Opinion

BY JUDGE JOHN J. MCGRATH, JR.

This action arises from a fatal automobile accident, which occurred on Interstate 81 on September 10, 1995, when the decedent was operating his automobile in a southerly direction on Interstate 81 in Smyth County, Virginia. [278]*278The Motion for Judgment alleges that the decedent’s car in which his wife was a passenger was hit by a Virginia State Police cruiser, which was in high-speed pursuit of another vehicle. The Plaintiff alleges that the state police cruiser was being operated by the Defendant, Trooper Michael D. Spangler, in a grossly negligent fashion at the time of the collision. The Motion for Judgment makes the standard allegations against the Defendant Spangler relating to his failure to operate his cruiser in an appropriate and reasonable fashion.

In addition, the Plaintiff asserts claims against the Commonwealth of Virginia in Paragraph 8 of the Motion for Judgment, which reads as follows:

8. The Commonwealth of Virginia acting by and through the Department of State Police was negligent in the following respects:
(a) Trooper Michael D. Spangler was at all times material to the allegations in this Motion for Judgment an employee of the Commonwealth of Virginia, Department of State Police, and acting within the scope of his employment. Therefore, the Commonwealth of Virginia is liable for all negligent acts of its employee by virtue of the doctrine of respondeat superior;
(b) The Department of State Police was negligent in its promulgation of rules, regulations, and protocols governing high-speed vehicular operation by State Troopers on public highways;
(c) The Department of State Police was negligent in permitting Trooper Michael D. Spangler to operate a State Police cruiser in the manner in which he did in this case when the Department knew, or in the exercise of reasonable diligence, should have known that Michael D. Spangler had a history of irresponsible vehicular operation and a pattern of the use of poor judgment causing property damage and endangerment to the public;
(d) The Department of State Police was negligent in failing to properly train Trooper Michael D. Spangler in the use of State Police vehicles in high-speed settings on public highways, thereby endangering the general public.

A companion suit has been filed by the surviving widow of Mr. John Paul Shenk, Sr., who was a passenger in his automobile at the time of the accident and sustained various personal injuries. These cases have been consolidated for trial before this Court.

The Attorney General’s Office, representing both defendants, has filed a responsive pleading in which it asserts a Plea of Immunity on behalf of Trooper Spangler. The Plea alleges that Trooper Spangler is entitled to [279]*279sovereign immunity, or, in the alternative, requests the Court to hold that the plaintiff must prove gross negligence to sustain a recovery against Trooper Spangler. The Commonwealth has also filed a demurrer alleging that its sovereign immunity to the claims asserted in paragraphs 8(b), (c), and (d) of the Motion for Judgment has not been waived by the Virginia Tort Claims Act (§§ 8.01-195.1 to 8.01-195.9 of the Code of Virginia). Thus, the Commonwealth argues, the Motion for Judgment does not state a cause of action against the Commonwealth as a matter of law.

The Commonwealth also argues that the allegations contained in Paragraph 8(b), (c), and (d) of the Motion for Judgment are subject to demurrer on one or more of the following theories:

(i) The Virginia Tort Claims Act only waives sovereign immunity for acts for which a “private person” would be liable. Because private persons do not and cannot train police officers, entrust vehicles to them, or publish regulations for high speed pursuits by law enforcement officers carrying out the enforcement of the laws, the Commonwealth has not waived immunity for these actions;
(ii) There is no recognized cause of action in Virginia for a failure to train employees; and

(iii) Since the statutory notices filed by the plaintiffs (pursuant to § 8.01-195.6 of the Virginia Tort Claims Act) only stated “death by wrongful act - vehicular homicide” and “personal injuries and property damage arising out of a motor vehicle collision,” they did not give the Commonwealth notice that claims would be made against it based on the State Police’s training procedures, rules, and regulations or for entrusting a state police cruiser to Trooper Spangler.

After hearing oral argument and reviewing extensive briefs from the parties and the pleadings, the Court believes it is now appropriate to rule upon the Plea of Sovereign Immunity asserted by Trooper Spangler and the Demurrer of the Commonwealth of Virginia.

I. Claim of Sovereign Immunity by Trooper Spangler

At this point, it is well established that a law enforcement officer operating a vehicle while in pursuit of alleged violators of the law is exercising a discretionary function and the officer is entitled to sovereign immunity. Moreover, applying the common law of Virginia, the Courts have consistently held that in order to recover in a tort action against an employee of the state [280]*280who is entitled to such sovereign immunity, it is necessary for the plaintiff to establish gross negligence. See, e.g., Colby v. Boyden, 241 Va. 125, 130 (1991).

Therefore, the Plea of Sovereign Immunity by Trooper Spangler will be granted insofar as the plaintiff will be required to establish gross negligence in order to have a recovery against Trooper Spangler.

II. Demurrer of the Commonwealth of Virginia

At the outset, it should be noted that the Commonwealth concedes that it is not entitled to be dismissed entirely from this case because, under the Virginia Tort Claims Act, it would be liable for negligence relating to the manner in which Trooper Spangler allegedly operated his cruiser on the date in question. However, the Commonwealth strenuously asserts that it is entitled to have its Demurrer sustained insofar as claims are made against the Commonwealth for the causes of action set forth in the following portions of the Motion for Judgment:

8(b). Negligence in the promulgation of rules, regulations, and protocols governing high-speed vehicular operation by state troopers on public highways;
8(c). Permitting Trooper Spangler to operate a state motor vehicle cruiser in the manner in which he did when the Department knew or in the exercise of reasonable diligence should have known that Trooper Spangler had a history of irresponsible vehicular operation and a pattern of the use of poor judgment causing property damage and endangerment to the public;
8(d). That the Commonwealth was negligent in failing to properly train Trooper Spangler in the use of state police vehicles in high-speed settings on public highways, thereby endangering the general public.

These sub-paragraphs of Paragraph 8 of the Motion for Judgment will be addressed in sequence.

1. The Negligent Promulgation of Rules, Regulations, and Protocols Governing High-Speed Vehicular Operation

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Bluebook (online)
46 Va. Cir. 277, 1998 Va. Cir. LEXIS 189, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shenk-v-spangler-vaccrockingham-1998.