Va. Code » Title 54.1. Professions and Occupations » Subtitle IV. Professions Regulated by the Supreme Court » Chapter 39. Attorneys » Article 1. General Provisions
Virginia Code

Va. Code Ann. § 54.1-3906 (2026)

Liability to client

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Every attorney shall be liable to his client for any damage sustained by the client through the neglect of his duty as such attorney.

Code 1950, § 54-46; 1988, c. 765; 2011, c. 703.

Notes of Decisions
Cited in 9 cases (3 in the last 5 years), 1995–2024 · leading case: Thorsen v. Richmond Soc'y for the Prevention of Cruelty to Animals, 786 S.E.2d 453 (Va. 2016).
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Thorsen v. Richmond Soc'y for the Prevention of Cruelty to Animals, 786 S.E.2d 453 (Va. 2016). · cites it 10× “2d 509, 512 (1951) (emphasis added) (quoting former Code § 54-46, predecessor to Code § 54.1-3906); see Code § 54.1-3906 (“Every attorney shall be liable to his client for any damage sustained by the client through the neglect of his duty as such attorney.”
In re Palumbo Fam. Ltd. P'ship, 182 B.R. 447 (Bankr. E.D. Va. 1995). · cites it 2× “Code § 54.1-3906 (Michie 1994). In contrast, the responsibilities connected with Rule 11 stem from a duty owed to the court.”
Hewlette v. Hovis, 318 F. Supp. 2d 332 (E.D. Va. 2004). · cites it 2× “Rather, Hovis asserts that the remaining claims, counts II through VI, must be dismissed because a breach of contract claim is the only claim a client may file against his attorney under Virginia law.”
Ripper v. Bain, 482 S.E.2d 832 (Va. 1997). · cites it 2× “The expert said that unless a lawyer went “through those steps,” advice upon whether or not the public had the right of access to the road’s upper portion would “constitute a breach of the standard of practice.”
McConnell v. Servinsky Eng'g, PLLC, 22 F. Supp. 3d 610 (W.D. Va. 2014). · cites it 2× “See Va. Code Ann. § 54.1-3906 (2013) ("Every attorney shall be liable to his client for any damage sustained by the client through the neglect of his duty as such attorney.”
Mark O'Hara Wright v. Andrew C. Graves, 892 S.E.2d 710 (Va. Ct. App. 2023). · cites it 2× “241 , 253 (2015)); see Code § 54.1-3906 (“Every attorney shall be liable to his client for any damage sustained by the client through the neglect of his duty as such attorney.”
Shevlin Smith v. McLaughlin, 289 Va. 241 (2015). · cites it 2× “Thus, the "any damage" to be recovered by operation of Code § 54.1-3906 in the event of an attorney's breach of his contractually implied duties is necessarily any contract damage, because the legal malpractice cause of action "is one for breach of contract.”
Mark O'Hara Wright v. Andrew C. Graves, 892 S.E.2d 710 (Va. Ct. App. 2023). · cites it 2× “241 , 253 (2015)); see Code § 54.1-3906 (“Every attorney shall be liable to his client for any damage sustained by the client through the neglect of his duty as such attorney.”
Melissa Trent v. Onderlaw, LLC, 902 S.E.2d 124 (Va. Ct. App. 2024). · cites it 2× “50 , 56 (2015)); see Code § 54.1-3906 (stating “[e]very attorney shall be liable to his client for any damage sustained by the client through the neglect of his duty as such attorney”).”
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