On June 5, 2014, the Virginia Supreme Court issued its opinion in the medical malpractice appeal of Bartee v. Vitocruz, No. 131283. “Applying the doctrine of survivorship, the power of appointment given [Robert] Bartee and Wiley Begley as co-administrators to prosecute a wrongful death action pursuant to Code §8.01-50 could be exercised by Bartee as the sole remaining administrator [after the death of Begley].” Id. at 10.