15 Mar Virginia: Special Cases – a Lawyer’s Sanctions
On February 26, 2015, the Virginia Supreme Court opined in EE Mart F.C., L.L.C. v. Delyon, No. 140708. It held that “under Code §8.01-271.1, a trial court may only award attorney’s fees incurred because of a filing or motion made to the trial court in the matter then pending before the court; it may not award attorney’s fees incurred for a filing or motion made elsewhere,” e.g., suits dismissed previously or in foreign jurisdictions. Id. at 6. Hence, EE Mart reversed and remanded for the amount of attorney’s fee sanctions awarded. Id. at 7.