Va. Code » Title 8.01. Civil Remedies and Procedure » Chapter 4. Limitations of Actions » Article 2. Limitations on Recovery of Realty and Enforcement of Certain Liens Relating to Realty
Virginia Code

Va. Code Ann. § 8.01-236 (2026)

Limitation of entry on or action for land

✓ current as of May 2026
Find cases: SyfertCases citing this section VA-LISlaw.lis.virginia.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

No person shall make an entry on, or bring an action to recover, any land unless within fifteen years next after the time at which the right to make such entry or bring such action shall have first accrued to such person or to some other person through whom he claims; provided that an action for unlawful entry or detainer under § 8.01-124 shall be brought within three years after such entry or detainer.

Code 1950, § 8-5; 1954, c. 604; 1977, c. 617; 1978, c. 471.

Notes of Decisions
Cited in 34 cases (8 in the last 5 years), 1979–2026 · leading case: Willner v. Frey, 421 F. Supp. 2d 913 (E.D. Va. 2006).
Sort: Relevance Newest Treatment
Willner v. Frey, 421 F. Supp. 2d 913 (E.D. Va. 2006). · cites it 15× “Count One alleged that the Commonwealth of Virginia, through the operation of Va.Code § 8.01-236, had taken the Willners’ property for public use without just compensation in violation of Article I, § 11 of the Virginia Constitution, and that the Willners were thereby entitled…”
Jones v. Jones, 457 S.E.2d 365 (Va. 1995). · cites it 6× “On April 12, 1994, 21 days after entry of the decree, the guardian ad litem filed written exceptions to the decree, alleging that the bill to commute dower was barred by the statute of limitations set forth in Code § 8.01-236, and that the bill was based on a statute that does…”
Willner v. Frey, 243 F. App'x 744 (4th Cir. 2007). · cites it 3× “In 2002 the Willners’ neighbor, Eugene Leggett, brought an ejectment action pursuant to Va.Code § 8.01-236 in the Fairfax County Circuit Court (Fairfax I), alleging that he had acquired an ownership interest in a portion of the Willners’ property through adverse possession.”
Helms v. Manspile, 671 S.E.2d 127 (Va. 2009). · cites it 2× “* We note that Code § 8.01-236 states in relevant part: "No person shall make an entry on, or bring an action to recover, any land unless within fifteen years next after the time at which the right to make such entry or bring such action shall have first accrued to such person…”
Quatannens v. Tyrrell, 601 S.E.2d 616 (Va. 2004). · cites it 2× “…entry of judgment for the Quatannens and such other action necessary to establish their title. Reversed and remanded. Code § 8.01-236.”
Payne v. Consolidation Coal Co., 607 F. Supp. 378 (W.D. Va. 1985). · cites it 6× “The plaintiffs have asserted a claim of trespass for the removal of the coal and the subsequent use of the drainway.”
Harkleroad v. Linkous, 704 S.E.2d 381 (Va. 2011). · cites it 4× “On November 25, 2008, the Linkouses filed an amended complaint in the circuit court against Appellants to quiet title to the property, asserting fee simple ownership on the *383 grounds of adverse possession for the statutory period of 15 years provided for by Code § 8.01-236.…”
Grappo v. Blanks, 400 S.E.2d 168 (Va. 1991). · cites it 2× “2d 227, 234 (1958); Code § 8.01-236. A claimant has the burden of proving all the elements of adverse possession by clear and convincing evidence.”
Hollander v. World Mission Church of Washington, D.C., 498 S.E.2d 419 (Va. 1998). · cites it 2× ““To establish title to real property by adverse possession, a claimant must prove actual, hostile, exclusive, visible, and continuous possession, under a claim of right, for the statutory period of 15 years.”
Young Kee Kim v. Douval Corp., 529 S.E.2d 92 (Va. 2000). · cites it 2× “2d 227, 234 (1958); Code § 8.01-236). The claimant bears the burden of proving the elements of adverse possession by clear and convincing evidence.”
McIntosh v. Chincoteague Volunteer Fire Co., 260 S.E.2d 457 (Va. 1979). · cites it 2× “2d 7, 9 (1971); Code § 8.01-236; 2 Minor on Real Property § 955 (2d ed.”
Calhoun v. Woods, 431 S.E.2d 285 (Va. 1993). · cites it 2× “See Code § 8.01-236. The burden is upon the claimant to prove all the foregoing elements by clear and convincing evidence.”
Show all 34 citing cases →
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.