Salzi v. Virginia Farm Bureau Mutual Insurance

I do not agree with the statement in the majority opinion that the barn belonging to the appellants, Victor H. and Lorraine Salzi, “was ‘used for business’ . . . because the Salzis permitted a farmer to store in their barn between 1,500 and 3,000 bales of hay related to the farmer’s tobacco business.” In my opinion, a one-time, gratuitous use of a barn to store a neighbor’s hay does not turn that bam into a “structure[] used for business.”

The storing of hay in this bam on one occasion lacks the continuity necessary to constitute a business use. See Virginia Mut. Ins. Co. v. Hagy, 232 Va. 472,…