Supreme Court of Virginia
Candice L. Filak v. Pamela S. George
April 23, 2004267 Va. 612
Summary
The court affirmed dismissal of the constructive-fraud claim and the directed verdict on the breach-of-contract claim. It held that the plaintiffs’ constructive-fraud allegations sought recovery for purely economic losses arising from duties created solely by the alleged oral contract, and therefore were governed by contract law rather than tort law. It further held that the plaintiffs failed to prove damages caused by the alleged breach because they presented no evidence of alternative financing costs or other delay-related losses.