47 Virginia opinions name it 17 courts 1987–2025 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.
| Case | Followed | Cited |
|---|---|---|
Bowman v. State Bank of Keysvillegreen2 sentences2025This employment at-will doctrine, however, “is not absolute.” Bowman, 229 Va. at 539 . 2016Bowman v. State Bank of Keysville , 229 Va. 534 , 331 S.E.2d 797 (1985). "[I]n our previous cases dealing with Bowman -type exceptions to the employment-at-will doctrine, this Court has consistently characterized such exceptions as 'narrow.' " City of Virginia Beach v. Harris , 259 Va. 220 , 232, 523 S.E.2d 239 , 245 (2000) (quoting Lawrence Chrysler Plymouth Corp. v. Brooks , 251 Va. 94 , 98, 465 S.E.2d 806 , 809 (1996) ). | 4 | 28 |
Miller v. Sevamp, Inc.green2 sentences2012We further stated that "Bowman recognized an exception to the employment-at-will doctrine limited to discharges which violate public policy." Id. at 468 , 362 S.E.2d at 918 (first emphasis added). 2012We further stated that "Bowman recognized an exception to the employment-at-will doctrine limited to discharges which violate public policy." Id. at 468 , 362 S.E.2d at 918 (first emphasis added). | 2 | 11 |
Lawrence Chrysler Plymouth Corp. v. Brooksgreen2 sentences2017In subsequent cases dealing with Bowman -type exceptions to the employment at-will doctrine, this Court has consistently characterized such exceptions as "narrow." Lawrence Chrysler Plymouth Corp. v. Brooks , 251 Va. 94 , 97-98, 465 S.E.2d 806 , 808-09 (1996) ; Lockhart v. Commonwealth Educ. 2017In subsequent cases dealing with Bowman -type exceptions to the employment at-will doctrine, this Court has consistently characterized such exceptions as "narrow." Lawrence Chrysler Plymouth Corp. v. Brooks , 251 Va. 94 , 97-98, 465 S.E.2d 806 , 808-09 (1996) ; Lockhart v. Commonwealth Educ. | 2 | 7 |
City of Virginia Beach v. Harrisgreen2 sentences2016Bowman v. State Bank of Keysville , 229 Va. 534 , 331 S.E.2d 797 (1985). "[I]n our previous cases dealing with Bowman -type exceptions to the employment-at-will doctrine, this Court has consistently characterized such exceptions as 'narrow.' " City of Virginia Beach v. Harris , 259 Va. 220 , 232, 523 S.E.2d 239 , 245 (2000) (quoting Lawrence Chrysler Plymouth Corp. v. Brooks , 251 Va. 94 , 98, 465 S.E.2d 806 , 809 (1996) ). 2016Bowman v. State Bank of Keysville , 229 Va. 534 , 331 S.E.2d 797 (1985). "[I]n our previous cases dealing with Bowman -type exceptions to the employment-at-will doctrine, this Court has consistently characterized such exceptions as 'narrow.' " City of Virginia Beach v. Harris , 259 Va. 220 , 232, 523 S.E.2d 239 , 245 (2000) (quoting Lawrence Chrysler Plymouth Corp. v. Brooks , 251 Va. 94 , 98, 465 S.E.2d 806 , 809 (1996) ). | 2 | 3 |
Stonega Coal & Coke Co. v. Louisville & Nashville Railroadgreen2 sentences2000See Stonega Coal and Coke Co. v. Louisville and Nashville R.R., 106 Va. 223 , 55 S.E. 551 (1906) (stating that Virginia adheres to the employment-at-will doctrine). 2000See Stonega Coal and Coke Co. v. Louisville and Nashville R.R., 106 Va. 223 , 55 S.E. 551 (1906) (stating that Virginia adheres to the employment-at-will doctrine). | 2 | 2 |
Lockhart v. Commonwealth Education Systems Corp.green2 sentences1995Although the Virginia Supreme Court in Lockhart v. Commonwealth Education Systems, 247 Va. 98 (1994), held in a 4 to 3 decision that the narrow exception of Bowman includes instances of termination because of discrimination based upon gender or race, it did state that it did “not retreat from [its] strong adherence to the employment-at-will doctrine.” 247 Va. at 106 . 1995Although the Virginia Supreme Court in Lockhart v. Commonwealth Education Systems, 247 Va. 98 (1994), held in a 4 to 3 decision that the narrow exception of Bowman includes instances of termination because of discrimination based upon gender or race, it did state that it did “not retreat from [its] strong adherence to the employment-at-will doctrine.” 247 Va. at 106 . | 1 | 5 |
Johnston v. William E. Wood & Assocs., Inc.green2 sentences2024Wood Assocs., 292 Va. 222, 225-26 (2016)). 2017Wood & Assocs. , 292 Va. 222 , 225-26, 787 S.E.2d 103 , 105 (2016) (citation and internal quotation marks omitted). | 1 | 2 |
Bailey v. Scott-Gallaher, Inc.green2 sentences2003After discussing prior holdings in employment termination cases, specifically noting that “Virginia strongly adheres to the common law employment-at-will doctrine,” 262 Va. at 68 (quoting Bailey v. ScottGallaher, Inc., 253 Va. 121, 123 , 480 S.E.2d 502 (1997)), the Court said: Applying the principles enunciated in our well-established precedent to the facts of this case, we hold that Wines failed to present evidence that he had an employment contract terminable solely for cause sufficient to rebut the employment at-will presumption. 2003After discussing prior holdings in employment termination cases, specifically noting that “Virginia strongly adheres to the common law employment-at-will doctrine,” 262 Va. at 68 (quoting Bailey v. ScottGallaher, Inc., 253 Va. 121, 123 , 480 S.E.2d 502 (1997)), the Court said: Applying the principles enunciated in our well-established precedent to the facts of this case, we hold that Wines failed to present evidence that he had an employment contract terminable solely for cause sufficient to rebut the employment at-will presumption. | 1 | 2 |
Dray v. New Market Poultry Products, Inc.green2 sentences2000As the Supreme Court recently stated in Dray v. New Market Poultry Products, 258 Va. 187, 190 , 518 S.E.2d 312 (1999): Virginia adheres to the common-law doctrine of employment-at-will. 2000As the Supreme Court recently stated in Dray v. New Market Poultry Products, 258 Va. 187, 190 , 518 S.E.2d 312 (1999): Virginia adheres to the common-law doctrine of employment-at-will. | 1 | 2 |
Haigh v. Matsushita Elec. Corp. of Americagreen2 sentences1992Corp. of America, 676 F. Supp. 1332 (E.D. 1990Furthermore, the United States District Court for the Eastern District of Virginia resounded the holding in Bowman with its statement that the narrow public policy exception carved out of the employment-at-will doctrine by the Virginia Supreme Court is "triggered only when the discharge is in response to the employee’s refusal to commit an unlawful act or in the employee’s exercise of a statutory right." Haigh v. Matsushita Electric Corp., 676 F. Supp. 1332, 1351 (E.D. | 1 | 2 |
Francis v. Nat'l Accrediting Comm'n of Career Arts & Sci., Inc.green1 sentence2024“Virginia adheres to the employment at-will doctrine, which allows that ‘[a]n employee remains at liberty to leave his employment for any reason or for no reason,’ and ‘[b]y the same token, the employer is free to terminate the employment relationship without the need to articulate a reason.” Francis v. Nat’l Accrediting Comm’n of Career Arts & Sciences, Inc., 293 Va. 167, 171-72 (2017) (alterations in original) (quoting Johnston v. William E. | 1 | 1 |
Mitchem v. Countsgreen2 sentences2002Mitchem v. Counts, 259 Va. 179, 190, 523 S.E.2d 246, 252 (2000). 2002Mitchem v. Counts, 259 Va. 179, 190, 523 S.E.2d 246, 252 (2000). | 1 | 1 |
Progress Printing Co., Inc. v. Nicholsgreen2 sentences2001See Progress Printing Co. v. Nichols, 244 Va. 337 , 421 S.E.2d 428, 429 (1992). 2001See Progress Printing Co. v. Nichols, 244 Va. 337 , 421 S.E.2d 428, 429 (1992). | 1 | 1 |
cluster 706000green2 sentences1997See Fuller v. Phipps, 67 F.3d 1137, 1141-42 (4th Cir. 1995). 1997See Fuller v. Phipps, 67 F.3d 1137, 1141-42 (4th Cir.1995). | 1 | 1 |
Duggin v. Adamsgreen1 sentence1994Ludwig does not directly allege any exception to the employment-at-will doctrine which would be admitted by demurrer but she is additionally entitled to admission of “facts which are by fair intendment impliedly alleged” and “facts which may be fairly and justly inferred from the facts alleged.” Bowman, supra, at 536 ; Duggin v. Adams, 234 Va. 221, 223 (1987). | 1 | 1 |
Addison v. Amalgamated Clothing & Textile Workers Uniongreen2 sentences1991Addison v. Amalgamated Clothing & Textile Workers Union of America, 236 Va. 233 , 372 S.E.2d 403, 405 (1988) (employer’s assurances that plaintiff could have a job "as long as he wanted one and as long as one existed” insufficient to rebut the presumption); Sullivan v. Snap-On Tools Corp., 708 F. Supp. 750 (E.D. 1991Addison v. Amalgamated Clothing & Textile Workers Union of America, 236 Va. 233 , 372 S.E.2d 403, 405 (1988) (employer’s assurances that plaintiff could have a job "as long as he wanted one and as long as one existed” insufficient to rebut the presumption); Sullivan v. Snap-On Tools Corp., 708 F. Supp. 750 (E.D. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Sea-Land Service, Inc. v. O'NEAL
green
2 sentences1988In Sea-Land Service, Inc. v. O’Neal, 224 Va. 343 , 297 S.E.2d 647 (1982) (promise of promotion to better job if employee resigned present job), and Twohy v. Harris, 194 Va. 69 , 72 S.E.2d 329 (1952) (promise of bonus measured by value of stock if employee remained on the job), the Court "found employment contracts to be supported by additional consideration sufficient to take the contracts out of the category of an employment at will." SEVAMP, supra, at 1313. 1987While Sea-Land involves a contract to rehire rather than a contract not to fire, the opinion states generally that the employment-at-will rule is rebuttable by a contrary agreement between employer and employee. 224 Va. at 349 . | 2 | 1987–1988 |
Rowan v. Tractor Supply Co.
green
2 sentences2007The Rowan court used even stronger language than the Harris court in rejecting obstruction of justice as a basis for a retaliatory discharge action, stating that “§ 18.2-460 did not create any statutory right or a corresponding public policy of the type that would support an exception to the employment-at-will doctrine and thus allow a common law action for wrongful termination.” 263 Va. at 215 , 559 S.E.2d at 712 . 2007The Rowan court used even stronger language than the Harris court in rejecting obstruction of justice as a basis for a retaliatory discharge action, stating that “§ 18.2-460 did not create any statutory right or a corresponding public policy of the type that would support an exception to the employment-at-will doctrine and thus allow a common law action for wrongful termination.” 263 Va. at 215 , 559 S.E.2d at 712 . | 1 | 2007–2007 |
Jordan v. Clay's Rest Home, Inc.
green
1 sentence2003Id. at 192 . | 1 | 2003–2003 |
Doss v. Jamco, Inc.
green
2 sentences1998Doss v. JAMCO, Inc., 254 Va. 362 , 492 S.E.2d 441 (1997). 1998Doss v. JAMCO, Inc., 254 Va. 362 , 492 S.E.2d 441 (1997). | 1 | 1998–1998 |
Texas Department of Community Affairs v. Burdine
green
2 sentences1997Indeed, in none of the Supreme Court cases is there even a passing reference to the doctrine, except in Burdine where there is a mention of “traditional management prerogatives.” 450 U.S. at 259 . 1997Indeed, in none of the Supreme Court cases is there even a passing reference to the doctrine, except in Burdine where there is a mention of "traditional management prerogatives." 450 U.S. at 259 , 101 S.Ct. at 1096 . | 1 | 1997–1997 |
Ruth v. Fletcher
green
2 sentences1997Accordingly, in order to sustain a cause of action for wrongful constructive discharge, this Court holds that a plaintiff must allege and prove by clear and convincing evidence (1) that the resignation was occasioned by conduct “so outrageous in character and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community,” Russo v. White, 241 Va. at 27 ; Ruth v. Fletcher, 237 Va. 366, 368 , 377 S.E.2d 412 (1989); and (2) that the conduct resulting in the resignation violated a Virginia public policy embodi 1997Accordingly, in order to sustain a cause of action for wrongful constructive discharge, this Court holds that a plaintiff must allege and prove by clear and convincing evidence (1) that the resignation was occasioned by conduct “so outrageous in character and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community,” Russo v. White, 241 Va. at 27 ; Ruth v. Fletcher, 237 Va. 366, 368 , 377 S.E.2d 412 (1989); and (2) that the conduct resulting in the resignation violated a Virginia public policy embodi | 1 | 1997–1997 |
Russo v. White
green
1 sentence1997Accordingly, in order to sustain a cause of action for wrongful constructive discharge, this Court holds that a plaintiff must allege and prove by clear and convincing evidence (1) that the resignation was occasioned by conduct “so outrageous in character and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community,” Russo v. White, 241 Va. at 27 ; Ruth v. Fletcher, 237 Va. 366, 368 , 377 S.E.2d 412 (1989); and (2) that the conduct resulting in the resignation violated a Virginia public policy embodi | 1 | 1997–1997 |
Sheets v. Teddy's Frosted Foods, Inc.
green
2 sentences1992In Sheets v. Teddy’s Frosted Foods, Inc., 179 Conn. 471 , 427 A.2d 385 (1980), plaintiff was employed by defendant, a producer of frozen food products, as a quality control director. 1992In Sheets v. Teddy’s Frosted Foods, Inc., 179 Conn. 471 , 427 A.2d 385 (1980), plaintiff was employed by defendant, a producer of frozen food products, as a quality control director. | 1 | 1992–1992 |
Seay v. Grace Jefferson Home
green
2 sentences1992While this court has recently recognized the existence of a public policy exception to Virginia’s employment-at-will doctrine (see Seay v. Grace Jefferson Home, 26 Va. Cir. 355 (1992)), such exception must be based on a specific, recognized, and established public policy: Bowman applied a “narrow exception to the employment-at-will rule,” . . . but it fell far short of recognizing a gener alized cause of action for the tort of “retaliatory discharge.” Declining to follow sweeping adoption of such a cause of action in other jurisdictions, Bowman recognized an exception to the employment-at-will 1992While this court has recently recognized the existence of a public policy exception to Virginia’s employment-at-will doctrine (see Seay v. Grace Jefferson Home, 26 Va. Cir. 355 (1992)), such exception must be based on a specific, recognized, and established public policy: Bowman applied a “narrow exception to the employment-at-will rule,” . . . but it fell far short of recognizing a gener alized cause of action for the tort of “retaliatory discharge.” Declining to follow sweeping adoption of such a cause of action in other jurisdictions, Bowman recognized an exception to the employment-at-will | 1 | 1992–1992 |
Sullivan v. Snap-On Tools Corp.
green
1 sentence1991Addison v. Amalgamated Clothing & Textile Workers Union of America, 236 Va. 233 , 372 S.E.2d 403, 405 (1988) (employer’s assurances that plaintiff could have a job "as long as he wanted one and as long as one existed” insufficient to rebut the presumption); Sullivan v. Snap-On Tools Corp., 708 F. Supp. 750 (E.D. | 1 | 1991–1991 |
Twohy v. Harris
green
2 sentences1988In Sea-Land Service, Inc. v. O’Neal, 224 Va. 343 , 297 S.E.2d 647 (1982) (promise of promotion to better job if employee resigned present job), and Twohy v. Harris, 194 Va. 69 , 72 S.E.2d 329 (1952) (promise of bonus measured by value of stock if employee remained on the job), the Court "found employment contracts to be supported by additional consideration sufficient to take the contracts out of the category of an employment at will." SEVAMP, supra, at 1313. 1988In Sea-Land Service, Inc. v. O’Neal, 224 Va. 343 , 297 S.E.2d 647 (1982) (promise of promotion to better job if employee resigned present job), and Twohy v. Harris, 194 Va. 69 , 72 S.E.2d 329 (1952) (promise of bonus measured by value of stock if employee remained on the job), the Court "found employment contracts to be supported by additional consideration sufficient to take the contracts out of the category of an employment at will." SEVAMP, supra, at 1313. | 1 | 1988–1988 |
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.