Taylor v. Northam

CourtSupreme Court of Virginia
DecidedSeptember 2, 2021
Docket210113
StatusPublished

This text of Taylor v. Northam (Taylor v. Northam) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Taylor v. Northam, (Va. 2021).

Opinion

PRESENT: All the Justices

HELEN MARIE TAYLOR, ET AL. OPINION BY v. Record No. 210113 JUSTICE S. BERNARD GOODWYN September 2, 2021 RALPH S. NORTHAM, ET AL.

FROM THE CIRCUIT COURT OF RICHMOND CITY W. Reilly Marchant, Judge In this appeal, we consider whether language in an 1890 deed, signed by the then

Governor of Virginia, and an 1889 joint resolution of the General Assembly, which requested

and authorized the Governor to sign such deed, prohibit the Governor of Virginia from ordering

the removal of a state-owned monument from state-owned property.

BACKGROUND

On July 15, 1887, the heirs of William C. Allen (the Allen heirs) conveyed by deed (the

1887 Deed) to the Lee Monument Association a round piece of property (the Circle) located at

the intersection of Monument Avenue and Allen Avenue, which is now in the City of Richmond,

Virginia. The terms of the 1887 Deed required the grantee, the Lee Monument Association, to

use the Circle as a site for a monument to Confederate General Robert E. Lee (General Lee), and

required the Lee Monument Association to hold the Circle “only for the said use.” Several

months later, the Lee Monument Association commissioned an equestrian statue of General Lee

and a pedestal (together, the Lee Monument) to be erected on the Circle.

On December 19, 1889, the General Assembly passed a joint resolution (the 1889 Joint

Resolution), authorizing and requesting the Governor at the time, P.W. McKinney (Governor

McKinney), to accept the donative transfer of the ownership of the Circle and the Lee Monument

from the Lee Monument Association to the Commonwealth of Virginia (the Commonwealth). In

the 1889 Joint Resolution, the General Assembly expressed its opinion that the Lee Monument Association proposed “the most graceful and appropriate disposition of the equestrian statue of

General Robert E. Lee [and land on which it is to be placed]” as a gift to the Commonwealth;

and “whereas this patriotic purpose is highly appreciated and approved by the General

Assembly,” it resolved to request and authorize the Governor to accept the gift and to give the

guarantee “of the state that it will hold the said [Lee Monument] perpetually sacred to the

monumental purpose to which it has been devoted.”

On March 17, 1890, upon the completion of the Lee Monument, the Lee Monument

Association executed a deed (the 1890 Deed) conveying ownership of the Lee Monument and

the Circle to the Commonwealth. Governor McKinney, who was also the president of the Lee

Monument Association at the time, signed the 1890 Deed on behalf of both the Commonwealth

and the Lee Monument Association. The Allen heirs also signed the 1890 Deed.

The 1890 Deed states that

The State of Virginia, party of the third part acting by and through the Governor of the Commonwealth and pursuant to the terms and provisions of the [1889 Joint Resolution] executes this instrument in token of her acceptance of the gift and of her guarantee that she will hold [the Lee Monument and the Circle] perpetually sacred to the Monumental purpose to which they have been devoted and that she will faithfully guard it and affectionately protect it.

The 1890 Deed also included a plat depicting the intended subdivision of the area surrounding

the Circle along Monument Avenue and Allen Avenue.

In 2020, the Commonwealth experienced an apparent rise in negative public sentiment

concerning the Lee Monument and other Confederate monuments, which was evidenced by civil

rights demonstrations and protests, as well as by damage being done to the Lee Monument and

other Confederate monuments.

On June 4, 2020, Governor Ralph S. Northam (Governor Northam) held a press

conference, at which he announced his intention to have the Lee Monument removed from the

2 Circle on Monument Avenue. Governor Northam thereafter directed and approved a Department

of General Services’ plan to remove the Lee Monument from the Circle.

In response to Governor Northam’s actions, on July 21, 2020, Helen Marie Taylor

(Taylor), John-Lawrence Smith (Smith), Janet Heltzel (Heltzel), George D. Hostetler (Hostetler),

and Evan Morgan Massey (Massey) (collectively, the Taylor Plaintiffs) filed a complaint in the

Circuit Court for the City of Richmond, seeking declaratory relief, preliminary injunctive relief,

and permanent injunctive relief against Governor Northam, Director Joe Damico of the Virginia

Department of General Services, and Director W. Michael Coppa of the Virginia Division of

Engineering and Building (collectively, the Governor). With the exception of Massey, the

Taylor Plaintiffs are owners of properties located on a portion of Monument Avenue that has

officially been designated as a National Historic Landmark District (the Historic District).

Massey is the trustee for an owner of property located in the Historic District. The properties in

which Heltzel, Hostetler, and Massey (collectively, the Allen heirs’ successors) hold an interest

are on the plat that is depicted in the 1890 Deed.

In their complaint, the Taylor Plaintiffs contend that Governor Northam has no authority

to remove the Lee Monument because the 1889 Joint Resolution binds him to perpetually

maintain the Lee Monument on the Circle. They argue that Governor Northam’s order violates

the Constitution of Virginia because his violation of the 1889 Joint Resolution encroaches upon

the legislature’s powers, violates the doctrine of separation of powers, and defies the

Commonwealth’s current public policy as expressed in the 1889 Joint Resolution. Additionally,

the Taylor Plaintiffs assert a property right to enforce the 1887 Deed and the 1890 Deed, which

they claim requires the Commonwealth to perpetually maintain the Lee Monument on the Circle.

3 Finally, they aver that removing the Lee Monument would violate Code § 2.2-2402(B), 1 which

they contend prohibits the removal of state-owned structures like the Lee Monument.

In response to the complaint, the Governor filed a demurrer, asserting that the complaint

fails to state a cause of action because Governor Northam, as the current Governor of Virginia,

has the authority to order the removal of the Lee Monument from the Circle. The Governor also

contends, in the demurrer, that the language in the 1887 Deed and the 1890 Deed which

purportedly restricts the Commonwealth’s use of the property given to it, is mere precatory

language, and thus the language in the 1887 Deed and the 1890 Deed is not sufficient to create

an enforceable property right (restrictive covenant) as alleged by the Taylor Plaintiffs. Further,

the Governor claims that, even if the language of the 1890 Deed creates a restrictive covenant, as

the Taylor Plaintiffs contend, that covenant is unenforceable because it violates public policy in

that the Commonwealth cannot be forced, in perpetuity, “to engage in expression with which it

disagrees.” Moreover, the Governor avers that “a compulsory [governmental] message violates

public policy, regardless of its content” and is therefore unenforceable, and also that

Code § 2.2-2402 does not provide a private right of action.

After a hearing on the matter, the circuit court granted the Taylor Plaintiffs’ request for a

temporary injunction and enjoined the Governor from removing the Lee Monument from the

Circle during the pendency of the case.

On August 25, 2020, the circuit court overruled the Governor’s demurrer as to the Taylor

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Taylor v. Northam, Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-v-northam-va-2021.