ejusdem generis doctrine (Virginia) · Go Syfert
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ejusdem generis doctrine in Virginia

10 Virginia opinions name it 6 courts 1962–2024 2 in the last five years

The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Standard Ice Co. v. Lynchburg Diamond Ice Factorygreen
va · 1921 · cited in 2 Virginia opinions naming this issue, 1989–2000
2 sentences

2000According to this rule, “where general words follow particular words, the former are to be regarded as applicable to file persons or things particularly mentioned.” Standard Ice Co. v. Lynchburg Ice, 129 Va. 521, 532 , 106 S.E. 390 (1921).

1989Under the doctrine of ejusdem generis, applicable to contracts and statutes alike, "where general words follow particular words, the former are to be regarded as applicable to the persons or things particularly mentioned; and the rule applies even if the general words are broad enough to cover other persons and things, unless something in the instrument [or statute] plainly indicates that they are to be otherwise applied." Standard Ice Company v. Lynchburg Ice, 129 Va. 521, 532 (1921).

12
Andrews v. Ringgreen
va · 2003 · cited in 1 Virginia opinions naming this issue, 2024–2024
1 sentence

2024See Andrews, 266 Va. at 319 ; Cuccinelli, 283 Va. at 432.

11
Turner v. Reedgreen
va · 1999 · cited in 1 Virginia opinions naming this issue, 2024–2024
1 sentence

2024Second, the deed allows the appellants to “plant and maintain grass, trees, shrubs, flowers and other landscaping” in the easement area and “enjoy 11 The items in this list stand in contrast to other language in the deed that specifically authorizes the appellants to repair or replace an “existing . . . dock,” as long as they do not expand its footprint. 12 Such principles apply not only to the construction of statutes but also to “legal instruments.” See Turner v. Reed, 258 Va. 406, 410 (1999) (analyzing a testatrix’s will in light of the doctrine of ejusdem generis); see also Talbott v. Rich

11
Kappa Sigma Fraternity, Inc. v. Kappa Sigma Fraternitygreen
va · 2003 · cited in 1 Virginia opinions naming this issue, 2006–2006
2 sentences

2006Under the doctrine of ejusdem generis “when items with a specific meaning are listed together in a statute and are followed by words of general import, the general words will not be construed to include matters within their broadest scope but only those matters of the same import as that of the specific items listed.” Kappa Sigma Fraternity, Inc. v. Kappa Sigma Fraternity, 266 Va. 455, 470 , 587 S.E.2d 701, 710 (2003).

2006Under the doctrine of ejusdem generis “when items with a specific meaning are listed together in a statute and are followed by words of general import, the general words will not be construed to include matters within their broadest scope but only those matters of the same import as that of the specific items listed.” Kappa Sigma Fraternity, Inc. v. Kappa Sigma Fraternity, 266 Va. 455, 470 , 587 S.E.2d 701, 710 (2003).

11
Johnson v. Roanoke Memorial Hospitals, Inc.green
vaccroanokecty · 1987 · cited in 1 Virginia opinions naming this issue, 1996–1996
1 sentence

1996Applying the interpretive doctrine of ejusdem generis, the term “communications” must be limited in its application to the particulars that proceed it, namely, the “proceedings, minutes, records, and reports of any medical staff committee, utilization review committee, or other committee as specified in § 8.01-581.16.” Judge Annunziata has observed that §§ 8.01-581.16 and 8.01-581.17 are “only intended to protect peer review committee proceedings and similar internal investigations of the hospital from public scrutiny.” Quoting Judge Coulter in his opinion in Johnson v. Roanoke Memorial Hospit

11
Sellers v. Blesgreen
va · 1956 · cited in 1 Virginia opinions naming this issue, 1992–1992
1 sentence

1992In Sellers v. Bles, 198 Va. 49, 56 (1956) (other citations omitted), the Supreme Court holds that the word improvement has no fixed and definite meaning, that “[i]t takes color and significance from its surroundings and must be interpreted and given the meaning indicated by its setting.” In interpreting the Covenants’ scope of the word improvement the Court finds the ejusdem generis rule applicable.

11
East Coast Freight Lines v. City of Richmondgreen
va · 1953 · cited in 1 Virginia opinions naming this issue, 1990–1990
1 sentence

1990East Coast Freight Lines v. City of Richmond, 194 Va. 517, 525 (1953).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Rockingham Co-Operative Farm Bureau, Inc. v. City of Harrisonburg green
va · 1938
1 sentence

2023Farm Bureau, 171 Va. at 344 — is what makes the ejusdem generis rule sensible.

12023–2023
Arnold v. Groobey green
va · 1953
2 sentences

1983It is only a rule of presumption and must yield to the testator’s intention, as expressed in the whole instrument.’ ” Arnold v. Groobey, 195 Va. at 226 , 77 S.E.2d at 389 .

1983It is only a rule of presumption and must yield to the testator’s intention, as expressed in the whole instrument.’ ” Arnold v. Groobey, 195 Va. at 226 , 77 S.E.2d at 389 .

11983–1983
Washington & Old Dominion Railway v. Westinghouse Electric & Manufacturing Co. green
va · 1917
1 sentence

1962Ry. v. Westinghouse Co., 120 Va. 620, 626 , 89 S. E. 131 , 133: “* * * The ejusdem generis rule is invoked only for the purpose of ascertaining the intent and meaning of the language under consideration, and should not be applied so as to do violence to the language employed in the instrument under consideration.” By the plain words of its contract Virginia-Carolina made itself responsible for all loss, damage or expense occasioned by any act of persons described, or of any other person having “anything whatsoever to do in connection with the work” of Virginia-Carolina.

11962–1962

Where else courts name it

IL 99 (1898–2026) TX 81 (1911–2025) CA 68 (1910–2025) WA 50 (1970–2024) PA 45 (1926–2026) MI 34 (1937–2023) NY 26 (1917–2024) NJ 19 (1965–2025) FL 18 (1927–2012) AL 17 (1915–2013) OH 16 (1944–2023) MD 16 (1970–2026) NC 15 (1957–2018) AZ 15 (1945–2017) UT 14 (1907–2020) IN 13 (1913–2024) AR 13 (1948–2025) OR 12 (1910–2019) MA 12 (1971–2026) TN 11 (1949–2021) OK 11 (1916–2008) KY 11 (1899–2022) LA 11 (1958–2021) VA 10 (1962–2024) WI 10 (1939–2015) HI 9 (1915–2019) NM 9 (1974–2014) CT 8 (1968–2013) MO 8 (1884–2023) MN 8 (1973–2018) IA 7 (1971–2019) ID 6 (1985–2018) KS 6 (1925–2020) CO 6 (1942–2023) WV 6 (1935–2024) MT 5 (1925–2009) NE 5 (1950–2005) RI 5 (1997–2026) MS 4 (1973–2000) NH 4 (1986–2019) WY 4 (1924–2015) GA 4 (1913–2021) ME 4 (1983–2021) DC 3 (1970–1991) ND 3 (1913–2007) AK 3 (2006–2019) SC 2 (1984–1995)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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