Virginia's Punitive Damages Cap

Virginia has capped punitive damages at $350,000 since before I practiced there in the late 90s and early 2000s.  Recently, the Fourth Circuit had to apply that damages cap to a case arising out of the August 2017 "Unite the Right" rally in Charlottesville.  The court held that the cap applies to each plaintiff and not each claim and that it applies broadly to all cases:

Sines v. Hill, 106 F.4th 341, 344, 352-354 (4th Cir. 2024) (Virginia law) (holding that the limit applies to each plaintiff and not each claim, regardless of the number of defendants; rejecting, additionally, the plaintiffs’ argument that the limit applies only to “ ‘run-of-the-mill tort claims’ ” and not to hate crimes such as those arising from the August 2017 “Unite the Right” rally of “ ‘white nationalists, white supremacists, and neo-Nazis’ ” in Charlottesville, Virginia).