Parson v. Carroll

Summary

The Supreme Court of Virginia held that a defendant's Alford pleas, which conceded only that the evidence was sufficient to support conviction, did not constitute factual admissions supporting judicial estoppel in a later defamation action. Because material factual allegations remained disputed, the circuit court erred in granting summary judgment. The court reversed and remanded, leaving open whether the plaintiff's criminal conduct could bar recovery under the illegal-acts doctrine.

Holdings

1. An Alford plea that concedes only the legal sufficiency of the evidence, without admitting participation in the criminal acts, is a position of law rather than a position of fact and therefore does not provide a basis for judicial estoppel.
2. The circuit court erred in granting summary judgment because the Alford pleas did not resolve the material factual allegations of Parson's defamation claim.

Questions Presented

1. Whether an Alford guilty plea, in which the defendant concedes only that the evidence is sufficient to support a conviction, constitutes a factual position subject to judicial estoppel in a later civil defamation action.
2. Whether the circuit court properly granted summary judgment when the material factual allegations in Parson's defamation action remained disputed.

Disposition

reversed_and_remanded