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7 Virginia opinions name it 3 courts 2007–2025 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.
| Case | Followed | Cited |
|---|---|---|
Fox v. Deesegreen2 sentences2014“However, the intra-corporate immunity doctrine, which has been adopted by the Virginia Supreme Court and the Fourth Circuit, deems multiple defendants a single entity for the purpose of analyzing a civil conspiracy claim if such defendants are employees or agents of the same entity and are acting within the scope of their employment/agency.” Fox v. Deese, 234 Va. 412, 428 , 362 S.E.2d 699, 708 (1987). 2014“However, the intra-corporate immunity doctrine, which has been adopted by the Virginia Supreme Court and the Fourth Circuit, deems multiple defendants a single entity for the purpose of analyzing a civil conspiracy claim if such defendants are employees or agents of the same entity and are acting within the scope of their employment/agency.” Fox v. Deese, 234 Va. 412, 428 , 362 S.E.2d 699, 708 (1987). | 2 | 3 |
Nedrich v. Jonesgreen2 sentences2015The intra-corporate immunity doctrine provides that, “there must be two persons to comprise a conspiracy, and a corporation, like an individual, cannot conspire with itself.” Nedrich v. Jones, 245 Va. 465, 473 (1993). 2013The intra-corporate immunity doctrine provides that, “there must be two persons to comprise a conspiracy, and a corporation, like an individual, cannot conspire with itself.” Nedrich v. Jones, 245 Va. 465, 473 , 429 S.E.2d 201 (quoting Bowman v. State Bank, 229 Va. 534, 541 , 331 S.E.2d 797 (1985)). | 1 | 2 |
Hyland v. RAYTHEON TECHNICAL SERVICES CO.green1 sentence2025Co., 277 Va. 40, 46 (2009)). 6 Massie also argues that the trial court erred by concluding that Ulta and Doe’s allegations were protected by the intra-corporate immunity doctrine and that she was required to plead to whom the defamatory remarks were made and the exact words of the defamatory statement. - 11 - Yet “[i]n the circumstances presented here, involving a plaintiff who is not a public official or public figure, and an alleged defamatory statement that imputes commission of a crime and thus makes substantial danger to reputation apparent, a negligence standard applies.” Melton, 250 Va. | 1 | 1 |
Dell v. Frenchgreen1 sentence2012“Since a corporation is merely a legal entity wholly created by law, it can act only through its agents, officers, and employees; therefore, a conspiracy between a corporation and the agents of that corporation who are acting in the scope of their employment is a legal impossibility.” Dell v. French, 38 Va. Cir. 91, 98 (Fairfax 1995). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Gazette, Inc. v. Harris
green
1 sentence2025Harris, 229 Va. at 15 . | 1 | 2025–2025 |
Food Lion, Inc. v. Melton
green
1 sentence2025Co., 277 Va. 40, 46 (2009)). 6 Massie also argues that the trial court erred by concluding that Ulta and Doe’s allegations were protected by the intra-corporate immunity doctrine and that she was required to plead to whom the defamatory remarks were made and the exact words of the defamatory statement. - 11 - Yet “[i]n the circumstances presented here, involving a plaintiff who is not a public official or public figure, and an alleged defamatory statement that imputes commission of a crime and thus makes substantial danger to reputation apparent, a negligence standard applies.” Melton, 250 Va. | 1 | 2025–2025 |
Bowman v. State Bank of Keysville
green
2 sentences2013The intra-corporate immunity doctrine provides that, “there must be two persons to comprise a conspiracy, and a corporation, like an individual, cannot conspire with itself.” Nedrich v. Jones, 245 Va. 465, 473 , 429 S.E.2d 201 (quoting Bowman v. State Bank, 229 Va. 534, 541 , 331 S.E.2d 797 (1985)). 2013The intra-corporate immunity doctrine provides that, “there must be two persons to comprise a conspiracy, and a corporation, like an individual, cannot conspire with itself.” Nedrich v. Jones, 245 Va. 465, 473 , 429 S.E.2d 201 (quoting Bowman v. State Bank, 229 Va. 534, 541 , 331 S.E.2d 797 (1985)). | 1 | 2013–2013 |
Sunsport, Inc. v. Barclay Leisure Ltd.
green
1 sentence2007When a plaintiff claims that a corporation and one of its employees conspires to injure the plaintiff, no conspiracy exists “because a corporation is a legal fiction capable of acting only through its officers and employees and is considered to be essentially only one officer.” Sunsport, Inc. v. Barclay Leisure, Ltd., 984 F. Supp. 418 (E.D. | 1 | 2007–2007 |
Lloyd v. Smith
green
1 sentence2007Id. | 1 | 2007–2007 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.