Stevens v. Jurnigan

Summary

The Supreme Court of Virginia held that the Court of Appeals applied the wrong standard of review when reviewing pleas in bar supported by deposition testimony and documentary evidence. The Court held that the circuit court’s factual findings were entitled to substantial deference and reinstated the circuit court’s determination that the plaintiff’s sexual-abuse claims accrued in 2002 and became time-barred in 2004.

Holdings

1. When the parties present evidence concerning a factual dispute underlying a plea in bar and submit the matter to the circuit court rather than a jury, the circuit court must resolve the factual dispute, and the appellate court must defer to the circuit court's factual findings.
2. The circuit court did not err in finding that Jurnigan's claims accrued when he reached the age of majority in 2002 and became time-barred two years later in 2004.

Questions Presented

1. What standard of appellate review applies when a circuit court resolves disputed factual issues underlying a plea in bar after considering deposition testimony and documentary evidence?
2. Whether the Court of Appeals erred by treating the evidentiary plea in bar as a motion for summary judgment and reviewing the circuit court's factual findings de novo.
3. Whether, under the deferential standard of review, the circuit court properly determined that Jurnigan's claims accrued when he reached the age of majority in 2002 and became time-barred in 2004.

Disposition

reversed