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School Board of Amherst County v. Burley
Citations: 225 Va. 376; 302 S.E.2d 53; 1983 Va. LEXIS 232Docket: Record No. 810097
Court: Supreme Court of Virginia; April 29, 1983; Virginia; State Supreme Court
In April 1980, J. Daniel and Mattie Burley sued the School Board of Amherst County, claiming a contract existed for the sale of their real estate and seeking specific performance. The School Board contended the contract was unenforceable under the Statute of Frauds due to lack of written documentation. The trial court found the Board estopped from asserting this defense and ordered specific performance. The Burley property was subject to a reciprocal negative easement with adjacent land owned by Timothy Whitehead, restricting use to residential purposes. Disputes arose when Whitehead offered to sell his land to the School Board, which the Burleys opposed, claiming it would violate the easement. During discussions on December 12, 1979, the Burleys expressed a willingness to sell their property, leading to an agreement on a purchase price of $82,500. Although the School Board members informally approved this, newly elected Supervisors later blocked the purchase after a legal opinion indicated the Board could proceed with buying Whitehead's property but not the Burleys'. The trial court ruled a contract existed between the Burleys and the Board, noting the Burleys relied on this contract by withdrawing opposition to the Whitehead purchase. However, the court's finding was challenged, as Code § 22-150 required school board contracts for real estate to be in writing, rendering any oral agreement void ab initio. The court's ruling of estoppel against the Board was deemed erroneous, as estoppel cannot apply to governmental entities in cases of ultra vires actions. The Commonwealth signed a contract with an arbitration clause and participated in arbitration, but later claimed it lacked the authority to enter into such an agreement when the plaintiff sought to enforce the arbitration award. The court agreed with the Commonwealth, determining it was not estopped from contesting the contract's validity despite its agents' involvement. Consequently, the court ruled that the Commonwealth was not bound by the contract, reversing the trial court's judgment and entering a final judgment for the School Board. Additionally, the excerpt references Code § 22-150, which mandated written contracts for real estate acquisitions by school boards, noting that this requirement was removed during the recodification to Title 22.1 in 1980.