Virginia Code
Va. Code Ann. § 8.01-34 (2026)
When contribution among wrongdoers enforced
✓ current as of May 2026
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Contribution among wrongdoers may be enforced when the wrong results from negligence and involves no moral turpitude.
Code 1950, § 8-627; 1977, c. 617.
Notes of Decisions
Cited in 52
cases (3 in the last 5 years), 1978–2025 · leading case: E.I. DuPont De Nemours & Co. v. Kolon Indus., Inc., 688 F. Supp. 2d 443 (E.D. Va. 2009).
E.I. DuPont De Nemours & Co. v. Kolon Indus., Inc., 688 F. Supp. 2d 443 (E.D. Va. 2009). “Kolon is therefore entitled to contribution from Mitchell and Aramid Fiber Systems pursuant to Va.Code § 8.01-34. TP Compl. at ¶¶ 22-24.”
Pulte Home Corp. v. Parex, Inc., 579 S.E.2d 188 (Va. 2003). “Contribution Pulte initially said on brief that its claim to contribution was based upon Code § 8.01-34, which provides that “[contribution among wrongdoers may be enforced when the wrong results from negligence and involves no moral turpitude.”
Virginia Elec. & Power Co. v. Wilson, 277 S.E.2d 149 (Va. 1981). “1919 [now Code § 8.01-34] gives a right of contribution only where the person injured has a right *981 of action against two persons for the same indivisible injury.”
Swisher v. Swisher & Craun, 290 S.E.2d 856 (Va. 1982). “This precedent became obsolete when Code § 5779 was added to the Code of 1919, (present Code § 8.01-34), providing contribution among negligent tortfeasors.”
Doe v. Virginia Wesleyan Coll., 90 Va. Cir. 345 (Norfolk Cir. Ct. 2015). “VWC Has Sufficiently Pleaded a Claim for Contribution against Roe In Virginia, there is a right to contribution amongst joint tortfeasors under certain circumstances, which are set out in § 8.01-34 of the Code of Virginia.”
Shiflet v. Eller, 319 S.E.2d 750 (Va. 1984). “Code § 8.01-34. The plaintiff also points to the settled rule of construction that statutes are usually presumed to be prospective and not retrospective in their operation, recognizing that legislative enactments may not impair contractual rights nor may vested property…”
Nw. Airlines, Inc. v. Transp. Workers Union, 451 U.S. 77 (1981). “Laws §§ 10-6-1 to 10-6-11 *88 (1969 and Supp. 1980); S.”
Pierce v. Martin, 334 S.E.2d 576 (Va. 1985). “This suit for contribution, Code § 8.01-34, 1 was brought by Lewis William Martin for the benefit of Commercial Union Insurance Company (Martin) against Clyde Wilson Pierce to recover $108,250, one-half the sum which Martin paid to certain injured parties.”
Mercury Mall Assocs., Inc. v. Nick's Mkt., Inc., 368 F. Supp. 2d 513 (E.D. Va. 2005). “Until Congress explicitly creates one, or until the United States Court of Appeals for the Fourth Circuit or the United States Supreme Court unequivocally holds that § 9607(a) implicitly provides for a contribution suit as a matter of federal common law, this Court will not…”
Sullivan v. Robertson Drug Co., Inc., 639 S.E.2d 250 (Va. 2007). “Sullivan was authorized under Code §§ 8.01-34 and-35.1 to pursue the contribution action.”
Watergate Landmark Condo. Unit Owners' Ass'n v. Wiss, Janey, Elstner Assocs., Inc., 117 F.R.D. 576 (E.D. Va. 1987). “Although a right of contribution is generally a proper basis on which to file a third party complaint, Virginia’s contribution statute does not apply to *579 this action.”
Safeway, Inc. v. DPI Midatlantic, Inc., 619 S.E.2d 76 (Va. 2005). “; see also Code § 8.01-34. For a compilation of cases holding that the exclusivity provisions of workers' compensation statutes do not prohibit the enforcement of express indemnity agreements between an employer and a third party, see Goodyear Tire, 629 So.”
— Va. Code Ann. § 8.01-34(f) — 1 case
Neblett v. Indus. Alloy Fabricators, Inc., 34 Va. Cir. 192 (Richmond County Cir. Ct. 1994).
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