The Virginia Supreme Court reversed the Court of Appeals in *Harris v. Joplin* (Va. 2025), ruling that the lower court erred in its analysis of extrinsic evidence admissibility for an illegible contract. Justice Thomas P. Mann wrote the opinion for the unanimous court, finding that the appeals court "misstated the burden of proof, applied the incorrect standard of review, and engaged in its own factfinding and ensuing weighing of the evidence."
The case stems from a June 2016 parking lot accident in which Terae Harris, driving an Enterprise rental car, backed out of a parking space and struck James Joplin, who was passing by on his motorcycle. The accident set in motion a complex chain of events involving a settlement offer and a liability-release contract that would later become central to the legal dispute.
Before Joplin filed suit, Enterprise sought to settle the matter. In December 2017, Galen Powell, a liability claims adjuster for Enterprise, emailed Joplin's attorney a one-page bodily injury release contract. The release offered Joplin the $25,000 policy limit in exchange for his release of all claims against both Enterprise and Harris. However, Powell never received a response to this settlement offer.
Joplin proceeded to sue Harris in the Circuit Court of Henrico County in May 2018, before the statute of limitations expired, seeking $300,000 in damages for negligent injury. The case continued without resolution of the settlement offer for nearly two years.
In April 2020, Powell still had not received any reply regarding Enterprise's settlement offer. He sent a follow-up letter by mail to Joplin's attorney, inquiring about the offer's status. Unknown to Powell, a different attorney at the same law firm, Theodore Briscoe, had taken over Joplin's case.
When Briscoe received Powell's follow-up letter, he searched his law firm's computer system for Joplin's release but could not locate it. He instructed a paralegal assigned to Joplin's case "to find the release so we can get that over to [Enterprise]." This search would prove significant to the eventual legal dispute.
On May 26, 2020, Briscoe and Powell spoke by telephone. During this conversation, Briscoe informed Powell that Joplin was interested in the settlement offer, though the full details of their discussion are not provided in the available court documents.
The legal dispute that reached the Virginia Supreme Court centered on the circuit court's decision to admit extrinsic evidence to prove the contents of what was described as an "illegible liability-release contract." The trial court apparently found that such evidence was admissible, but a panel of the Court of Appeals disagreed.
The Court of Appeals reversed the circuit court's decision, holding that the court erred because "the proponent of the evidence had not met her burden of proof for admissibility." This ruling suggested that Harris, as the party seeking to introduce the extrinsic evidence, had failed to meet the required legal standard for admitting such evidence in place of the original contract document.
However, the Virginia Supreme Court found multiple errors in the Court of Appeals' analysis. The high court identified three specific problems with the appeals court's approach: misstating the burden of proof required for admissibility of extrinsic evidence, applying an incorrect standard of review, and improperly engaging in factfinding and weighing evidence.
The Supreme Court's reversal indicates that courts must apply the correct legal standards when determining whether extrinsic evidence can be used to prove the contents of contracts that are illegible or otherwise unavailable. The burden of proof and standard of review are crucial elements that determine how trial courts should evaluate such evidence and how appellate courts should review those decisions.
This case highlights the complexities that can arise in contract disputes when original documents become illegible or disputed. The admissibility of extrinsic evidence to prove contract terms is governed by specific evidentiary rules that courts must apply correctly to ensure fair proceedings.
The Virginia Supreme Court's decision provides important guidance for lower courts handling similar evidentiary issues in contract cases. By clarifying the appropriate burden of proof and review standards, the ruling helps establish consistent application of evidence rules across the Virginia court system.
The case also demonstrates how seemingly straightforward contract disputes can become complicated when documentation issues arise. From a 2016 parking lot accident to a 2025 Supreme Court decision, *Harris v. Joplin* illustrates the potential longevity and complexity of civil litigation involving contract interpretation and evidence admissibility.
The full implications of this decision will likely become clearer as lower courts apply the Supreme Court's guidance in future cases involving illegible contracts and extrinsic evidence. Legal practitioners handling contract disputes in Virginia will need to carefully consider the correct burden of proof standards established by this ruling.