Knodel v. Dickerman

In this appeal of a judgment approving a jury’s verdict in a wrongful death action, we consider whether a child, adopted after the death of the decedent, but before the jury’s verdict was entered, may recover damages as a statutory beneficiary under Code § 8.01-53.

The relevant facts are not in dispute. Charlotte Elizabeth Dickerman, a 13-year-old, died from injuries she incurred in a one-vehicle accident in Shenandoah County. John L. Dickerman, administrator of Charlotte’s estate, filed this wrongful death action against Karl Philip Knodel, the driver, and others, seeking damages for…