Va. Code » Title 27. Fire Protection » Chapter 2. Fire/EMS Departments and Fire/EMS Companies » Article 1. Provisions Applicable to Counties, Cities and Towns
Virginia Code

Va. Code Ann. § 27-23.6 (2026)

Repealed

✓ current as of May 2026
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Repealed by Acts 2015, cc. 502 and 503, cl. 2.

Notes of Decisions
Cited in 10 cases, 1991–2014 · leading case: Nat'l R.R. Passenger Corp. v. Catlett Volunteer Fire Co., 404 S.E.2d 216 (Va. 1991).
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Nat'l R.R. Passenger Corp. v. Catlett Volunteer Fire Co., 404 S.E.2d 216 (Va. 1991). · cites it 37× “immune from suit pursuant to Virginia Code §27-23.6, 1950 as amended? b. [Does] Miller [have] qualified immunity and can only be liable if his actions are found to constitute gross negligence? The pertinent facts are set forth in the Fourth Circuit’s order of certification: On…”
Friday-Spivey v. Collier, 601 S.E.2d 591 (Va. 2004). · cites it 4× “The trial court sustained the Fire Department's plea in bar and dismissed it from the case with prejudice pursuant to the provisions of Code § 27-23.6(B) in effect at that time.”
Poppenheimer v. Est. of Coyle, 98 So. 3d 1059 (Miss. 2012). “2d 216 (citing Va.Code Ann. § 27-23.6). No such statutory authority exists in Mississippi.”
Boyce v. City of Winchester, 39 Va. Cir. 21 (Winchester Cir. Ct. 1995). · cites it 6× “Va. Code Ann. § 27-23.6 (B) provides that: any .”
Leahy v. Am. Med. Response, 49 Va. Cir. 349 (Richmond County Cir. Ct. 1999). · cites it 8× “By virtue ofVa. Code § 27-23.6: A. Any county, city or town may contract with or provide for any volunteer fire-fighting or rescue companies or associations in the county, city or town for the fighting of fire or provision of rescue services in any county, city or town.”
Bosserman v. Hayes, 89 Va. Cir. 84 (Augusta Cir. Ct. 2014). · cites it 4× “Code § 27-23.6(B) did not eliminate the requirement that, in order to enjoy the protection of sovereign immunity, the operator of the vehicle be exercising some degree of discretion beyond that required for ordinary driving situations.”
Toms v. Greene Cnty. Rescue Squad, 48 Va. Cir. 520 (Charlottesville Cir. Ct. 1999). · cites it 6× “Under Va. Code § 27-23.6, Virginia cities or counties may enter into associations with volunteer fire and rescue squads, and those entities will be treated as instrumentalities of the city or county.”
Mooney v. Guardian Emergency Med. Servs., Inc., 89 Va. Cir. 360 (Wythe Cir. Ct. 2014). · cites it 3× “Va. Code §§ 27-23.6(A), (B) (2013). A court uses a four-part test to evaluate whether an entity is entitled to immunity as an instrumentality: (1) the nature and function of the entity, (2) the extent of the state’s interest and involvement in that function, (3) the degree of…”
Daddio v. Ashley, 43 Va. Cir. 283 (Loudoun Cir. Ct. 1997). · cites it 2× “Ashley asserts that his conduct does not, as a matter of law, constitute gross negligence entitling the plaintiff to recovery. The General Assembly has specifically provided that volunteer firefighting companies are deemed to be instrumentalities of local government and…”
Campbell Cnty. v. Altavista Lifesaving & First Aid Crew, Inc., 75 Va. Cir. 491 (Campbell Cir. Ct. 2007). “3 (reimbursement for advances from governing bodies); § 27-23.6 (governing body allowed to contract with volunteer organizations to provide services); and § 38.”
— Va. Code Ann. § 27-23.6(A) — 2 cases
Mooney v. Guardian Emergency Med. Servs., Inc., 89 Va. Cir. 360 (Wythe Cir. Ct. 2014). “Va. Code §§ 27-23.6(A), (B) (2013). A court uses a four-part test to evaluate whether an entity is entitled to immunity as an instrumentality: (1) the nature and function of the entity, (2) the extent of the state’s interest and involvement in that function, (3) the degree of…”
Leahy v. Am. Med. Response, 49 Va. Cir. 349 (Richmond County Cir. Ct. 1999). “By virtue ofVa. Code § 27-23.6: A. Any county, city or town may contract with or provide for any volunteer fire-fighting or rescue companies or associations in the county, city or town for the fighting of fire or provision of rescue services in any county, city or town.”
— Va. Code Ann. § 27-23.6(B) — 3 cases
Friday-Spivey v. Collier, 601 S.E.2d 591 (Va. 2004). “The trial court sustained the Fire Department's plea in bar and dismissed it from the case with prejudice pursuant to the provisions of Code § 27-23.6(B) in effect at that time.”
Boyce v. City of Winchester, 39 Va. Cir. 21 (Winchester Cir. Ct. 1995). “Va. Code Ann. § 27-23.6 (B) provides that: any .”
Bosserman v. Hayes, 89 Va. Cir. 84 (Augusta Cir. Ct. 2014). “Code § 27-23.6(B) did not eliminate the requirement that, in order to enjoy the protection of sovereign immunity, the operator of the vehicle be exercising some degree of discretion beyond that required for ordinary driving situations.”
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