Haynes v. Haggerty, 291 Va. 301

Summary

The Supreme Court of Virginia held that Nancy Haynes's claims arising from alleged childhood sexual abuse accrued when the injuries occurred and that the applicable limitations period expired before the enactment of Code § 8.01-249(6). Applying Code § 8.01-256, the court concluded that the later-enacted accrual provision did not apply and affirmed dismissal of the action as time-barred.

Holdings

1. Code § 8.01-249(6) does not apply to Haynes's claims because the causes of action existed before October 1, 1977, and Code § 8.01-256 provides that Chapter 4's limitations provisions do not apply to such causes of action.
2. The Court may affirm a correct judgment on a different legal rationale when the record supports the alternative ground, including when the rationale was not raised by a party or addressed by the trial court.
3. The Court did not decide whether retroactive application of Code § 8.01-249(6) would violate due process or impair a vested property right because the statutory issue resolved the appeal.

Questions Presented

1. Whether Code § 8.01-249(6), which provides a later accrual date for actions arising from childhood sexual abuse when the injury and causal connection are communicated by a qualified professional, applied to Haynes's claims.
2. Whether Code § 8.01-256 excluded application of Code § 8.01-249(6) because Haynes's causes of action existed before October 1, 1977.
3. Whether the circuit court's judgment could be affirmed under the right-result-for-the-wrong-reason doctrine without deciding the constitutional challenge to retroactive application of Code § 8.01-249(6).

Disposition

affirmed