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8 Virginia opinions name it 4 courts 2004–2025 4 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.
| Case | Followed | Cited |
|---|---|---|
Williams v. Consolvogreen2 sentences2025The voluntary-payment doctrine is well-established in Virginia: Where a person with full knowledge of the facts voluntarily pays a demand unjustly made upon him, though attempted or threatened to be enforced by proceedings, it will not be considered as paid by compulsion, and the party thus paying is not entitled to recover back the money paid, though he may have protested against the unfounded claim at the time of payment made. - 15 - Williams v. Consolvo, 237 Va. 608, 613 (1989) (emphasis omitted) (quoting Wessel, Duval & Co. v. Winborne & Co., 125 Va. 502, 510 (1919)). 2025The circumstances in which “exceptions” to the voluntary-payment doctrine have been permitted are “decidedly few.” Williams, 237 Va. at 613 . | 2 | 3 |
Criterion Insurance v. Fulghamgreen2 sentences2025Id. at 300 ; see id. at 298-300 . 2006Co. v. Fulgham, 219 Va. 294 (1978), argues that it would be an inequitable result in this case to follow the voluntary payment rule. | 2 | 3 |
Wessel, Duval & Co. v. Winborne & Co.green2 sentences2025The voluntary-payment doctrine is well-established in Virginia: Where a person with full knowledge of the facts voluntarily pays a demand unjustly made upon him, though attempted or threatened to be enforced by proceedings, it will not be considered as paid by compulsion, and the party thus paying is not entitled to recover back the money paid, though he may have protested against the unfounded claim at the time of payment made. - 15 - Williams v. Consolvo, 237 Va. 608, 613 (1989) (emphasis omitted) (quoting Wessel, Duval & Co. v. Winborne & Co., 125 Va. 502, 510 (1919)). 2025The voluntary-payment doctrine is well-established in Virginia: Where a person with full knowledge of the facts voluntarily pays a demand unjustly made upon him, though attempted or threatened to be enforced by proceedings, it will not be considered as paid by compulsion, and the party thus paying is not entitled to recover back the money paid, though he may have protested against the unfounded claim at the time of payment made. - 15 - Williams v. Consolvo, 237 Va. 608, 613 (1989) (emphasis omitted) (quoting Wessel, Duval & Co. v. Winborne & Co., 125 Va. 502, 510 (1919)). | 2 | 2 |
Town of Phoebus v. Manhattan Social Clubgreen2 sentences2013See also Town of Phoebus, 105 Va. at 149 , 52 S.E. at 840 ("The mere declaration of the plaintiff when it made payment, that it was made under 'protest' does not show that it was not voluntarily made."). 2009Phoebus v. Manhattan Social Club, 105 Va. 144 (1906); Charlottesville v. Marks’ Shows, Inc., 179 Va. 321 (1942); Crestwood Constr. | 1 | 2 |
Lamborn v. County Commissionersgreen1 sentence2013And the fact that the party at the time of making the payment, files a written protest, does not make the payment involuntary." Barrow v. County of Prince Edward, 121 Va. 1, 2-3 , 92 S.E. 910, 910 (1917) (quoting Lamborn v. County Commissioners, 97 U.S. 181, 187 (1878)). | 1 | 1 |
Jones' Administrators v. Colemangreen2 sentences2013And the fact that the party at the time of making the payment, files a written protest, does not make the payment involuntary." Barrow v. County of Prince Edward, 121 Va. 1, 2-3 , 92 S.E. 910, 910 (1917) (quoting Lamborn v. County Commissioners, 97 U.S. 181, 187 (1878)). 2013Barrow, 121 Va. at 2 , 92 S.E. at 910 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Citizens Bank & Trust Co. v. Crewe Factory Sales Corp.
green
2 sentences2025Put simply, “the voluntary-payment doctrine recognizes that at some point, reviewing courts should declare litigation to be at an end when the litigants themselves—by their own voluntary actions—have effectively ended it.” Id. 2024“In the appellate context, the voluntary-payment doctrine recognizes that at some point, reviewing courts should declare litigation to be at an end when the litigants themselves — by their own voluntary actions — have effectively ended it.” Id. | 2 | 2024–2025 |
Barrow v. County of Prince Edward
green
2 sentences2013And the fact that the party at the time of making the payment, files a written protest, does not make the payment involuntary." Barrow v. County of Prince Edward, 121 Va. 1, 2-3 , 92 S.E. 910, 910 (1917) (quoting Lamborn v. County Commissioners, 97 U.S. 181, 187 (1878)). 2013Barrow, 121 Va. at 2 , 92 S.E. at 910 . | 1 | 2013–2013 |
City of Charlottesville v. Marks' Shows, Inc.
green
1 sentence2009Phoebus v. Manhattan Social Club, 105 Va. 144 (1906); Charlottesville v. Marks’ Shows, Inc., 179 Va. 321 (1942); Crestwood Constr. | 1 | 2009–2009 |
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.