Steve Thomas Jurnigan, II filed suit in 2017 against Michael H. Stevens, James M. Bowes, and the Southampton Bowmen Club, alleging sexual abuse that occurred from 1993-2000 when Jurnigan was between 8 and 15 years old. The complaint alleged that Francis M. Monahan sexually abused Jurnigan on the club's property, with Stevens and Bowes serving as club officers during that period. Jurnigan claimed he was unaware of the causal connection between the abuse and his injuries until receiving psychotherapy in 2014.
Writing for a unanimous court, Justice Teresa M. Chafin held that the Court of Appeals 'applied the wrong standard of review' when it treated the defendants' pleas in bar as summary judgment motions and reviewed the case de novo without giving deference to the circuit court's factual findings. The circuit court had granted the defendants' pleas in bar after considering deposition testimony and documentary evidence, concluding that Jurnigan knew the abuse caused him injuries before reaching majority age in 2002, making his 2017 lawsuit time-barred under the then-applicable two-year statute of limitations.
The Supreme Court emphasized the fundamental difference between pleas in bar and summary judgment motions, writing that 'At the risk of stating the obvious, we emphasize that the deposition testimony and accompanying exhibits presented by the appellants constituted substantive evidence in this case.' Justice Chafin noted that unlike summary judgment, 'a plea in bar may require the resolution of disputed factual issues' and when evidence is presented, appellate courts must defer to circuit court findings unless they are 'plainly wrong or without evidentiary support.'
The Sussex County Circuit Court had relied on Jurnigan's own written statements to police during the criminal investigation, where he described having 'flashback[s] and almost PTSD[-]like symptoms from images burned in [his] mind of the physical abuse [he] had endured.' The circuit court determined this evidence showed Jurnigan 'knew . . . he was suffering from anxiety, irritability, and other issues' that he 'related . . . back to the sexual abuse' while still a student, causing his claims to accrue when he reached majority in 2002 rather than when he received therapy in 2014.
The Court of Appeals had reversed the circuit court in January 2025, concluding that genuine disputes of material fact existed about when Jurnigan became aware of the causal connection between his abuse and injuries. But the Supreme Court rejected this analysis, writing that the appeals court 'committed a significant error when it treated the appellants' pleas in bar as motions for summary judgment' and 'committed another significant error when it failed to give any deference to the circuit court's factual findings.'
The ruling clarifies Virginia's standard of review for pleas in bar where evidence has been presented, with Justice Chafin emphasizing that 'we review factfinding with the highest degree of appellate deference.' The court noted that judgments based on depositions, while 'not as strong and conclusive as one based on evidence heard ore tenus,' are still 'presumptively correct, and cannot be disturbed if [they are] reasonably supported or sustained by substantial, competent, and credible evidence.'
The decision effectively ends Jurnigan's lawsuit against the archery club defendants, as his claims are now definitively time-barred under the 2002 statute of limitations that required suits to be filed within two years of reaching majority age. The ruling also provides important guidance for practitioners on the standards governing pleas in bar, particularly emphasizing that such pleadings can resolve disputed factual issues and are entitled to deferential review when supported by evidence, unlike summary judgment motions which cannot be granted when material facts are genuinely disputed.