Jakabcin v. Town of Front Royal

CHARLES S. RUSSELL, Senior Justice.

In this case of first impression in Virginia, we must determine whether a local governing body may convene and conduct a valid meeting with less than a quorum of its members physically present, when absent members had disqualified themselves from acting pursuant to the State and Local Government Conflict of Interests Act, Code §§ 2.2-3100 et seq. (COIA).

Facts and proceedings

The essential facts are undisputed. In 2002, Wal-Mart Real Estate Business Trust (Wal-Mart) was the contract purchaser of a 121-acre parcel of land in the Riverton area of the Town of…