time-honored principle in Virginia

2026The fact that Code § 40.1-28.7:8 allows an employer to bar its former employees from soliciting its clients becomes even more apparent when considering “the time-honored principle - 14 - expressio unius est exclusio alterius.” Miller & Rhoads Bldg. v. City of Richmond, 292 Va. 537, 544 (2016) (quoting Va. Dep’t of Health v. NRV Real Est., LLC, 278 Va. 181, 187 (2009)).

2024Code § 2.2-3705.1(1) provides that no provision of VFOIA “shall be construed as denying public access to (i) contracts between a public body and its officers or employees, other than contracts settling public employee employment disputes . . . .” In construing statutes, courts have “‘consistently applied the time-honored principle expressio unius est exclusio alterius,’ because this maxim ‘recognizes the competence of the legislature to choose its words with care.’” Miller & Rhoads Bldg., L.L.C. v. City of Richmond, 292 Va. 537, 544 (2016) (quoting Virginia Dep’t of Health v. NRV Real Estate,

2026The fact that Code § 40.1-28.7:8 allows an employer to bar its former employees from soliciting its clients becomes even more apparent when considering “the time-honored principle - 14 - expressio unius est exclusio alterius.” Miller & Rhoads Bldg. v. City of Richmond, 292 Va. 537, 544 (2016) (quoting Va. Dep’t of Health v. NRV Real Est., LLC, 278 Va. 181, 187 (2009)).

2024Code § 2.2-3705.1(1) provides that no provision of VFOIA “shall be construed as denying public access to (i) contracts between a public body and its officers or employees, other than contracts settling public employee employment disputes . . . .” In construing statutes, courts have “‘consistently applied the time-honored principle expressio unius est exclusio alterius,’ because this maxim ‘recognizes the competence of the legislature to choose its words with care.’” Miller & Rhoads Bldg., L.L.C. v. City of Richmond, 292 Va. 537, 544 (2016) (quoting Virginia Dep’t of Health v. NRV Real Estate,

2005"It is a time-honored principle of evidence law that, in general, if evidence is admissible for any purpose, it is admissible----Absent extreme prejudice, a party should not be precluded from offering probative evidence on a material issue merely because the evidence would be inadmissible if offered for some other purpose.” Hanson v. Commonwealth, 14 Va.App. 173, 183 , 416 S.E.2d 14, 20 (1992) (citation omitted).

2005"It is a time-honored principle of evidence law that, in general, if evidence is admissible for any purpose, it is admissible----Absent extreme prejudice, a party should not be precluded from offering probative evidence on a material issue merely because the evidence would be inadmissible if offered for some other purpose.” Hanson v. Commonwealth, 14 Va.App. 173, 183 , 416 S.E.2d 14, 20 (1992) (citation omitted).

2023As the circuit court was not plainly wrong in ruling that West’s statements constituted party admissions, we need not address whether the statements also satisfied a different hearsay exception.1 See Davis, 73 Va. App. at 509 (“[I]t is a time-honored principle of evidence law that, in general, if evidence is admissible for any purpose, it is admissible.” (quoting Brown v. Commonwealth, 25 Va. App. 171, 178 (1997))). 1 As we affirm the trial court’s judgment admitting the progress note and West’s statement therein under the business record exception and the party admission doctrine, we do not a

2021In such circumstances, “it should be remembered that it is a time-honored principle of evidence law that, in general, if evidence is admissible for any purpose, it is admissible.” Brown, 25 Va. App. at 178 .

1997In that regard, however, it should be remembered that it is a time-honored principle of evidence law that, in general, if evidence is admissible for any purpose, it is admissible.” Jenkins v. Commonwealth, 22 Va.App. 508, 521 , 471 S.E.2d 785, 791 (1996) (en banc) (quoting 2 Charles E.

1997In that regard, however, it should be remembered that it is a time-honored principle of evidence law that, in general, if evidence is admissible for any purpose, it is admissible.” Jenkins v. Commonwealth, 22 Va.App. 508, 521 , 471 S.E.2d 785, 791 (1996) (en banc) (quoting 2 Charles E.

2026Indeed, the Supreme Court “has recognized that ‘“[n]o maxim of the law is of more general or uniform application [than expressio unius], and it is never more applicable than in the construction and interpretation of statutes.”’” Id. (first alteration in original) (collecting cases) (quoting Whitehead v. Cape Henry Syndicate, 105 Va. 463, 471 (1906)).

2024Homeowners Ass’n, Inc., 291 Va. 269, 277 (2016)).

2024This principle also applies when “a [written instrument] covers particular or express matters.” Yukon Pocahontas Coal Co. v. Ratliff, 181 Va. 195, 203 (1943) (quoting 16 Am.

2010Shipman, 267 Va. at 502-03 , 593 S.E.2d at 323 ; Virginia Military Inst. v. King, 217 Va. 751, 759 , 232 S.E.2d 895, 900 (1977).

2010Shipman, 267 Va. at 502-03 , 593 S.E.2d at 323 ; Virginia Military Inst. v. King, 217 Va. 751, 759 , 232 S.E.2d 895, 900 (1977).

2005See also United States v. Abel, 469 U.S. 45, 56 , 105 S.Ct. 465, 471 , 83 L.Ed.2d 450 (1984) ("CTjhere is no rule of evidence which provides that testimony admissible for one purpose and inadmissible for another purpose is thereby rendered inadmissible; quite the contrary is the case.”). .

2005See also United States v. Abel, 469 U.S. 45, 56 , 105 S.Ct. 465, 471 , 83 L.Ed.2d 450 (1984) ("CTjhere is no rule of evidence which provides that testimony admissible for one purpose and inadmissible for another purpose is thereby rendered inadmissible; quite the contrary is the case.”). .

2005The distinction is not material to the result under “the time-honored principle of evidence law that, in general, if evidence is admissible for any purpose, it is admissible.” Hanson v. Commonwealth, 14 Va. App. 173, 183 , 416 S.E.2d 14, 20 (1992); see also Rosenberg v. Mason, 157 Va. 215, 236 , 160 S.E. 190, 197 (1931) (noting “cardinal rule of evidence that evidence relevant and material for one purpose is not rendered inadmissible for that purpose by the fact that it is inadmissible for some other purpose”); Gonzales v. Commonwealth, 45 Va. App. 375 , 388 n.5, -9- wrong or lacks evidentiary

2005The distinction is not material to the result under “the time-honored principle of evidence law that, in general, if evidence is admissible for any purpose, it is admissible.” Hanson v. Commonwealth, 14 Va. App. 173, 183 , 416 S.E.2d 14, 20 (1992); see also Rosenberg v. Mason, 157 Va. 215, 236 , 160 S.E. 190, 197 (1931) (noting “cardinal rule of evidence that evidence relevant and material for one purpose is not rendered inadmissible for that purpose by the fact that it is inadmissible for some other purpose”); Gonzales v. Commonwealth, 45 Va. App. 375 , 388 n.5, -9- wrong or lacks evidentiary

2005Commonwealth v. Jenkins, 255 Va. 516, 520 , 499 S.E.2d 263, 265 (1998).

2005Commonwealth v. Jenkins, 255 Va. 516, 520 , 499 S.E.2d 263, 265 (1998).