acceleration clause (Virginia) · Go Syfert
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acceleration clause in Virginia

9 Virginia opinions name it 4 courts 1919–2025 1 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 (8)

CaseFollowedCited
Devany v. Colgingreen
va · 1935 · cited in 2 Virginia opinions naming this issue, 1942–2025
2 sentences

2025See Code § 6.2-401(A) (“Any note or other contract evidencing an installment loan or other installment sales obligation with add-on interest may provide that the entire unpaid loan balance, at the option of the holder, shall become due and payable upon default in payment of any installment without impairing the negotiability of the note.”); Code § 6.2-1614(5) (prohibiting an acceleration clause that “permit[s] the unpaid balance of a mortgage loan to be declared due for any reason other than failing to make timely payments of interest and principal”); Devany v. Colgin, 163 Va. 848, 850 (1935)

1942Devany v. Colgin, 163 Va. 848 , 178 S. E. 15 .

12
Snyder v. Exumgreen
va · 1984 · cited in 2 Virginia opinions naming this issue, 1986–1990
2 sentences

1990In Snyder v. Exum, 227 Va. 373 , 315 S.E.2d 216 (1984), the court had to determine if a rent acceleration clause was mandatory or optional, and if mandatory, whether that clause required the lessor to institute suit to collect all the rent in one proceeding. 3 The acceleration clause in Snyder is legally identical with that contained in the instant cases.

1990In Snyder v. Exum, 227 Va. 373 , 315 S.E.2d 216 (1984), the court had to determine if a rent acceleration clause was mandatory or optional, and if mandatory, whether that clause required the lessor to institute suit to collect all the rent in one proceeding. 3 The acceleration clause in Snyder is legally identical with that contained in the instant cases.

12
Teachers' Retirement System v. American Title Guaranty Corp.green
vaccfairfax · 1996 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025Corp., 38 Va. Cir. 316, 316-18 (Fairfax 1996) (“Where a landlord of commercial property may mitigate his damages by re-letting the property, but the tenant is contractually bound to pay future rents regardless of whether the property is re-let, the acceleration clause potentially requires payment grossly in excess of actual damages.”).

11
Nickels v. People's Building, Loan & Saving Ass'ngreen
va · 1896 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025See Code § 6.2-401(A) (“Any note or other contract evidencing an installment loan or other installment sales obligation with add-on interest may provide that the entire unpaid loan balance, at the option of the holder, shall become due and payable upon default in payment of any installment without impairing the negotiability of the note.”); Code § 6.2-1614(5) (prohibiting an acceleration clause that “permit[s] the unpaid balance of a mortgage loan to be declared due for any reason other than failing to make timely payments of interest and principal”); Devany v. Colgin, 163 Va. 848, 850 (1935)

11
Fant v. Thomasgreen
va · 1921 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025See Code § 6.2-401(A) (“Any note or other contract evidencing an installment loan or other installment sales obligation with add-on interest may provide that the entire unpaid loan balance, at the option of the holder, shall become due and payable upon default in payment of any installment without impairing the negotiability of the note.”); Code § 6.2-1614(5) (prohibiting an acceleration clause that “permit[s] the unpaid balance of a mortgage loan to be declared due for any reason other than failing to make timely payments of interest and principal”); Devany v. Colgin, 163 Va. 848, 850 (1935)

11
Boots, Inc. v. Prempal Singhgreen
va · 2007 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025See Code § 6.2-401(A) (“Any note or other contract evidencing an installment loan or other installment sales obligation with add-on interest may provide that the entire unpaid loan balance, at the option of the holder, shall become due and payable upon default in payment of any installment without impairing the negotiability of the note.”); Code § 6.2-1614(5) (prohibiting an acceleration clause that “permit[s] the unpaid balance of a mortgage loan to be declared due for any reason other than failing to make timely payments of interest and principal”); Devany v. Colgin, 163 Va. 848, 850 (1935)

11
Belnord Realty Co. v. Levisongreen
· 1923 · cited in 1 Virginia opinions naming this issue, 1984–1984
2 sentences

1984See Belnord Realty Co. v. Levison, 204 A.D. 415, 418 , 198 N.Y.S. 184, 186 (1923).

1984See Belnord Realty Co. v. Levison, 204 A.D. 415, 418 , 198 N.Y.S. 184, 186 (1923).

11
White v. Commonwealthgreen
va · 1932 · cited in 1 Virginia opinions naming this issue, 1982–1982
2 sentences

1982In White v. Commonwealth, 158 Va. 749, 757 , 164 S.E. 375, 377 (1932), we quoted Stonega Coal & Coke Co. v. Louisville & N.R.Co., 106 Va. 223 , 55 S.E. 551 (1906), stating our general view in construing written contracts: While the court, in construing a contract, may take into view the circumstances under which it was made, yet when a breach of it is averred its language must determine to what the parties to it bound themselves.

1982In White v. Commonwealth, 158 Va. 749, 757 , 164 S.E. 375, 377 (1932), we quoted Stonega Coal & Coke Co. v. Louisville & N.R.Co., 106 Va. 223 , 55 S.E. 551 (1906), stating our general view in construing written contracts: While the court, in construing a contract, may take into view the circumstances under which it was made, yet when a breach of it is averred its language must determine to what the parties to it bound themselves.

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 (7)

CaseCitedYears
O'BRIAN v. Langley School green
va · 1998
1 sentence

2025See Code § 6.2-401(A) (“Any note or other contract evidencing an installment loan or other installment sales obligation with add-on interest may provide that the entire unpaid loan balance, at the option of the holder, shall become due and payable upon default in payment of any installment without impairing the negotiability of the note.”); Code § 6.2-1614(5) (prohibiting an acceleration clause that “permit[s] the unpaid balance of a mortgage loan to be declared due for any reason other than failing to make timely payments of interest and principal”); Devany v. Colgin, 163 Va. 848, 850 (1935)

12025–2025
Lerner v. Gudelsky Co. green
va · 1985
2 sentences

1988Lerner v. The Gudelsky Co., 230 Va. 124 , 334 S.E.2d 579 (1985), clearly requires contractual conditions precedent to be met in order for liability to attach.

1988Lerner v. The Gudelsky Co., 230 Va. 124 , 334 S.E.2d 579 (1985), clearly requires contractual conditions precedent to be met in order for liability to attach.

11988–1988
cluster 391375 green
ca1 · 1981
1 sentence

1982As indicated in Williams v. First Federal, 651 F.2d at 923-24 , if this be a restraint on alienation, it is one validated by Virginia law as an inescapable conclusion from this statutory enactment. *139 Borrowers and Purchaser would have us read into the acceleration clause a proviso that in the event of a sale or transfer the acceleration clause would not be operative unless the transfer or sale would impair the security of the lender or otherwise increase its risk.

11982–1982
Crockett v. FIRST FEDERAL S. & L. ASS'N, ETC. green
nc · 1976
2 sentences

1982The Supreme Court of North Carolina faced this identical problem in Crockett v. First Federal Savings, etc., 289 N.C. 620 , 625-26, 224 S.E.2d 580 , 584 (1976), and said: One factor that significantly affects the nature of this acceleration clause so far as the restraints doctrine is concerned is the fact that the creditor’s right to accelerate arises only when the realty is alienated.

1982The Supreme Court of North Carolina faced this identical problem in Crockett v. First Federal Savings, etc., 289 N.C. 620 , 625-26, 224 S.E.2d 580 , 584 (1976), and said: One factor that significantly affects the nature of this acceleration clause so far as the restraints doctrine is concerned is the fact that the creditor’s right to accelerate arises only when the realty is alienated.

11982–1982
Stonega Coal & Coke Co. v. Louisville & Nashville Railroad green
va · 1906
2 sentences

1982In White v. Commonwealth, 158 Va. 749, 757 , 164 S.E. 375, 377 (1932), we quoted Stonega Coal & Coke Co. v. Louisville & N.R.Co., 106 Va. 223 , 55 S.E. 551 (1906), stating our general view in construing written contracts: While the court, in construing a contract, may take into view the circumstances under which it was made, yet when a breach of it is averred its language must determine to what the parties to it bound themselves.

1982In White v. Commonwealth, 158 Va. 749, 757 , 164 S.E. 375, 377 (1932), we quoted Stonega Coal & Coke Co. v. Louisville & N.R.Co., 106 Va. 223 , 55 S.E. 551 (1906), stating our general view in construing written contracts: While the court, in construing a contract, may take into view the circumstances under which it was made, yet when a breach of it is averred its language must determine to what the parties to it bound themselves.

11982–1982
Rench v. Rench green
iowa · 1918
1 sentence

1921In Rench v. Rench, 184 Iowa 1372 , 169 N. W. 667 , there was a devise to the wife for life, remainder at the death of the wife to his daughter “if living, or to her issue, if any, if she be dead; and if she be dead'without issue” then to a nephew.

11921–1921
Slocum v. Hagaman green
ill · 1898
1 sentence

1919And when it is the evident intention of the testator that the remainder should not take effect till the expiration of the life of the prior donee, the remainder will not be accelerated.” Three of the eight judges sitting in this case dissented, but the conclusion of the majority of the court seems to be approved in Slocum v. Hagaman, 196 Ill., 533 , 539, 52 N. E. 332 .

11919–1919

Where else courts name it

NY 100 (1910–2025) TX 54 (1925–2025) CA 45 (1927–2025) FL 44 (1927–2024) GA 34 (1934–2003) MI 33 (1930–2025) PA 24 (1928–2019) LA 23 (1933–2025) IL 22 (1904–2025) OH 22 (1912–2017) MA 21 (1956–2022) NJ 19 (1929–2024) IA 17 (1925–2022) AZ 16 (1969–2022) KS 16 (1915–2022) OK 15 (1936–2024) MO 14 (1927–2016) IN 13 (1936–2020) TN 13 (1915–2018) CT 12 (1933–2002) AR 11 (1924–1982) AL 11 (1929–2017) CO 10 (1954–2020) NC 10 (1948–2024) MD 10 (1954–2002) WA 10 (1929–2026) ND 10 (1918–1997) VA 9 (1919–2025) MS 9 (1955–2021) ME 8 (1973–2024) MN 7 (1924–1986) WI 7 (1929–2018) NM 7 (1941–2024) OR 7 (1919–1999) NE 7 (1926–2022) UT 7 (1935–2019) SD 6 (1927–1982) DE 6 (1930–2017) RI 4 (1974–2018) ID 3 (1922–1988) KY 3 (1937–1998) VT 3 (1993–2005) MT 3 (1923–1962) HI 3 (1997–2013) SC 2 (1940–1984) WY 2 (1933–1981)

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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