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IN THE COMMONWEALTH OF VIRGINIA

IN THE CIRCUIT COURT OF HENRICO COUNTY

JAMES MEDEIROS, MAURICIO No. _____________________

TOVAR, BLUE WING LLC, and
ROBERT PIERCE, PETITION
FOR DECLARATORY
Plaintiffs, JUDGMENT AND THE
IMPANELING OF A
v. JURY FOR THE
DETERMINATION OF
VIRGINIA DEPARTMENT OF JUST COMPENSATION
WILDLIFE RESOURCES,

Defendant.

James Medeiros, Mauricio Tovar, Blue Wing LLC, and Robert

Pierce (“Blue Wing” and, collectively, “Plaintiffs”) each own properties in

the Commonwealth of Virginia (“Commonwealth”) that are posted with

“No Trespassing” signs, which properties have been overrun frequently

by hunting dogs and their owners. 1 The dogs run loose and loudly on

Plaintiffs’ properties, disturbing the peace of their private homes,

agricultural uses, and leased hunting cabins, chasing deer and

presenting a safety risk to Plaintiffs’ clients, livestock, and families.

1 Robert Pierce is a member of Blue Wing LLC’s corporate board. He

tends and operates the property owned by Blue Wing LLC.

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These invasions occur because of Virginia’s “right to retrieve” law, Va.

Code § 18.2-136, which takes from Virginians their right to decide who

may enter their property, at what times, and under what conditions.

The invading hunters act largely without permission and in

flagrant disregard for the “No Trespassing” signs posted on each of the

Plaintiffs’ properties. Virginia Code § 18.2-136 (“Right to Retrieve Law”)

gives hunters the special privilege to enter private land when carrying

on a hunt for foxes or coons with dogs, and to also physically retrieve their

dogs when hunting for any type of game, including deer. The

constitutions of both Virginia and the United States regard the right to

exclusive ownership of property as fundamental. The Right to Retrieve

Law robs Mr. Medeiros, Mr. Tovar, Blue Wing, Mr. Pierce, and all other

Virginians of their right to exclude hunters and their dogs from private

property.

It is well settled that when property is taken for a public use,

including a grant of access in favor of a preferred group, the government

must pay just compensation for the value of the property interest taken.

Cedar Point Nursery v. Hassid, 141 S. Ct. 2063, 2074 (2021). The

Commonwealth’s enforcement arm for this law, the Department of

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Wildlife Resources, therefore, must pay the constitutionally mandated

just compensation owed to Plaintiffs for the damage and diminution in

value resulting from the confiscation of their rights to exclude hunters

and dogs from their private lands.

CONCISE STATEMENT OF THE CASE

1. Virginia’s Right to Retrieve Law, codified under Virginia Code

§ 18.2-136, has taken the above-named Plaintiffs’ right to exclude

hunters and their dogs from their private properties, which right of

exclusion is a fundamental attribute of property ownership.

2. Plaintiffs bring this Petition for Declaratory Judgment and

pray for relief in the form of (1) a judgment declaring that Virginia’s

“right to retrieve” law works an uncompensated physical taking of their

property in violation of Article I, § 11 of the Virginia Constitution and the

Fifth Amendment to the United States Constitution as applied against

the Commonwealth through the Fourteenth Amendment to the U.S.

Constitution; (2) the impaneling of a jury to determine the measure of

just compensation; and (3) all appropriate attorneys’ fees and costs.

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 JURISDICTION & VENUE

3. This Court has subject-matter jurisdiction over Plaintiffs’

petition for a declaratory judgment pursuant to Va. Code § 8.01-184 and

the demand for constitutional just compensation for a taking pursuant to

Va. Code § 8.01-187, Va. Const. art. I, § 11, and U.S. Const. amends. V,

XIV.

4. Venue is proper in this Court pursuant to Virginia Code

§ 8.01-261, as the Department is an agency of the Commonwealth and is

headquartered in Henrico County, Virginia, at 7870 Villa Park Drive, No.

400, Richmond, VA 23228.

PARTIES

Plaintiffs

5. Plaintiffs are a group of private landowners, some of whom

are hunters themselves, or use and lease their own land for hunting, who

have suffered repeated and routine invasions of their properties

authorized by Virginia’s Right to Retrieve Law and seek compensation

for the deprivation of their right to exclude interloping hunters from their

lands.

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 6. James Medeiros and his family own approximately 143

acres of real property located in Dinwiddie County at 5301 White Oak

Road in Wilsons, Virginia 23894 whereon they reside in a private home

(hereinafter “Medeiros Property”).

7. The Medeiros Property is posted with “No Trespassing” signs

around its perimeter everywhere it borders a wooded area and

conspicuously at the entrance to its private driveway.

8. Mr. Medeiros and his family operate numerous agricultural

and other business ventures on the Medeiros Property, including a

sawmill, dairy farm, poultry farm, and honey-gathering operation

marketed under the brand White Oak Meadows.

9. Because of Mr. Medeiros’s business ventures, he keeps on this

property between 700 and 1,000 free-ranging layer and broiler chickens,

approximately 55 head of cattle, used for milk and USDA-certified grass-

fed beef, 15 beehives, and 150 guinea hens used for natural pest control.

10. The broiler chickens and grass-fed cattle are pastured on the

property, requiring the animals regularly to be rotated through the

various pasture and wooded sections of the property.

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 11. To Mr. Medeiros’ knowledge, none of the property owners

neighboring the Medeiros Property within a half-mile own dogs.

12. Robert Pierce operates approximately 1,100 acres of real

property in Halifax County located at 5223 Virgilina Highway, Virgilina,

VA 24598 (hereinafter “Blue Wing Property”), which is posted with “No

Trespassing” signs. The property is owned by Plaintiff Blue Wing LLC.

13. Mr. Pierce acquired the Blue Wing Property in April of 1994

and operates 1,026 acres of it predominately as a recreational hunting

area through Blue Wing LLC.

14. The Blue Wing Property contains a hunting cabin, 39 hunting

blinds, and is leased to guests for the purpose of hunting deer, quail,

rabbit, and turkey.

15. The Blue Wing Property has two miles of frontage on Virgilina

Highway and 11 gates that control ingress and egress for the property.

16. Blue Wing LLC is a corporation incorporated in the

Commonwealth of Virginia. It owns the 1,100 acres of real property in

Halifax County located at 5223 Virgilina Highway, Virgilina, VA 24598.

Plaintiff Robert Pierce is a member of the governing board for Blue Wing

LLC and operates the Blue Wing Property.

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 17. In addition to leasing land for hunting purposes, Blue Wing

LLC conducts business on the Blue Wing Property as a Certified Tree

Farm, exercising sustainable forestry best management practices,

including a Long Leaf Pine restoration project.

18. Blue Wing LLC also maintains 20 miles of hiking and

horseback riding trails for use by its members and a 500-yard rifle range.

There are “Keep-Out / Guns in Use” signs along its perimeter.

19. Mauricio Tovar owns approximately 30 acres of real

property in Chesterfield County located at 15421 River Road,

Chesterfield, VA 23838 (hereinafter “Tovar Property”) where he lives

with his wife and four children.

20. The property is posted with “No Trespassing” signs, including

signs that are conspicuously visible to drivers entering the property

through its private drive from the adjacent street.

21. Mr. Tovar also has his own hunting dog named Jack that lives

on the Tovar Property. Jack, unlike the dogs that routinely overrun the

Tovar property during hunting season, is well trained to recall. Mr. Tovar

does not allow Jack to run free on others’ private property.

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 22. The Tovar Property contains a family home, barn, horse

pasture, and horse-riding ring.

23. Mr. Tovar uses the barn’s 10 horse stalls and the horse-riding

ring for his horse-boarding business, which is often disrupted during the

hunting season by interloping hunting dogs.

24. The barn also contains a coop for approximately 12-18

chickens, which are pasture-fed and free-ranged on the Tovar Property.

25. Since 2019, when Mr. Tovar purchased the property, dogs

have been a repeated invasive nuisance on the Tovar Property during

Virginia’s deer-hunting season between October and January.

26. The dogs run through the Tovar Property, including into the

horse-riding ring and chase the chickens near the family home,

presenting a threat to the health and safety of Mr. Tovar, his family, his

clients, and anyone else working with horses on the property during

hunting season.

27. Mr. Tovar is concerned over the risk of liability that a hunting

dog causes a horse-related incident involving a client and the cost of time

spent rounding up dogs on his property.

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 28. Typically, during a hunting season, hunters enter the

property not less than three times without permission, despite the

property’s “No Trespassing” signs, to retrieve their dogs. The dogs

themselves are a regular and routine menace during hunting seasons.

29. Mr. Tovar recognizes the dogs as hunting dogs because of

their breeds and distinctive orange collars, and the hunters as hunters

by their orange hats, other apparel, and accoutrement, including dog

boxes in the backs of their trucks.

30. Hunters entering the property to retrieve their dogs have told

Mr. Tovar that they have the right under Virginia law to do so, even

without his permission.

Defendant

31. The Virginia Department of Wildlife Resources

(hereinafter “Department”) is a department of the Commonwealth

responsible for the regulation of hunting within the Commonwealth and

enforcement of the laws and regulations of the Commonwealth and

Department respecting hunting, including but not limited to Va. Code

§ 18.2-136.

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 32. On information and belief, the Department’s Law

Enforcement Division has responsibility for dealing with hunting-dog-

related complaints and employs over 100 conservation police officers for

dealing with those complaints.

33. The Virginia Code provides that “[a]ll sheriffs, police officers

or other peace officers of this Commonwealth shall be ex officio

conservation police officers[,]” Va. Code § 29.1-202, “[c]onservation police

officers shall have jurisdiction throughout the Commonwealth to enforce

the hunting, trapping and inland fish laws[,]” Va. Code § 29.1-203(A), and

“conservation police officers shall assist the Director [of the Department]

in discharging his official duties.” Va. Code § 29.1-204.

CONCISE STATEMENT OF DISPOSITIVE FACTS

34. Plaintiffs reallege, adopt, and incorporate by reference the

foregoing paragraphs as though fully set forth herein.

35. Plaintiffs own properties located respectively in Dinwiddie

County, Chesterfield County, and Halifax County, Virginia.

36. All of Plaintiffs’ properties are conspicuously marked with

“No Trespassing” signs.

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 37. Virginia’s Right to Retrieve Law grants “[f]ox hunters and

coon hunters” a statutory right to enter Plaintiffs’ properties in pursuit

of game with their hunting dogs “when the chase begins on other lands.”

Va. Code § 18.2-136.

38. The Right to Retrieve Law also grants “hunters of all other

game” the statutory power to enter Plaintiffs’ properties “to retrieve their

dogs.” Va. Code § 18.2-136.

39. Under the Right to Retrieve Law, hunters “can lawfully

retrieve dogs even when access has been expressly denied by the

landowner.” Virginia Department of Game and Inland Fisheries, A

Report on Deer Hunting with Dogs 3 (Jan. 2016) (Department of Game

and Inland Fisheries subsequently renamed Virginia Department of

Wildlife Resources), available at https://dwr.virginia.gov/wp-

content/uploads/deer-hunting-with-dogs.pdf.

40. Defendant, the Virginia Department of Wildlife Resources, is

responsible for the enforcement of the Right to Retrieve Law.

41. Plaintiffs have each suffered repeated invasions of their

private properties by hunters and hunting dogs since they have owned

and operated their separate properties whereby hunting dogs run loose

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on their properties and hunters enter their properties to follow and to

collect their dogs. For each Plaintiff, these invasions have occurred as

recently as this past deer-hunting season in Virginia.

42. Plaintiffs have suffered a diminution in the value of their

properties by having their right to exclude hunters and their hunting

dogs from their private properties.

43. On March 15, 2022, Plaintiffs mailed a letter to Ryan Brown,

the Executive Director of the Department of Wildlife Resources,

demanding that the Department initiative condemnation proceedings

concerning their properties for the value and interest taken by the

continued enforcement of the Right to Retrieve Law. See Exhibit 1.

44. The Department responded to that letter, declining to initiate

condemnation proceedings or otherwise provide for the payment of just

compensation to which Plaintiffs are constitutionally entitled. See

Exhibit 2.

FACTUAL ALLEGATIONS

The Medeiros Property

45. Plaintiffs reallege, adopt, and incorporate by reference the

foregoing paragraphs as though fully set forth herein.

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 46. The Medeiros Property has been subject to repeated invasions

by hunters and their dogs acting under color of lawful authority according

to Va. Code § 18.2-136 since Mr. Medeiros acquired the property. These

invasions have occurred as recently as Virginia’s past deer-hunting

season.

47. During the first deer-hunting season following Mr. Medeiros’

acquisition of the property, he and his wife were alarmed by the sight and

sound of approximately 20 hunting dogs circling their house, chasing

their chickens and baying loudly.

48. When Mr. Medeiros confronted a hunter standing nearby

wearing an orange cap, the hunter informed him that “we [the local

hunting club] have permission to hunt this property.”

49. Then-Lieutenant Scott Naff of the Virginia Department of

Wildlife Resources, with whom Mr. Medeiros spoke the following week,

informed Mr. Medeiros that the Virginia Code’s Right to Retrieve Law

allowed hunters access to the Medeiros Property at the hunters’

discretion to send and retrieve their dogs and that there was nothing

Mr. Medeiros or the Department could do about it.

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 50. The intrusions on the Medeiros Property have continued

predictably each deer-hunting season between October and January

when hunting dogs enter the property, disturb the cattle, run loose

through the pastures where the Medeiros’ animals feed. The dogs bark

and howl loudly around the Medeiros’ private home, and kill their

chickens.

51. Mr. Medeiros recognizes the dogs as hunting dogs according

to their orange collars, breeds, and the hunters wearing orange caps,

camouflage, and other accoutrement of recreational hunting, sometimes

including firearms, who enter the Medeiros Property to retrieve them.

52. Hunters’ dogs enter the Medeiros Property without leave on

most days during hunting season often including multiple dogs, multiple

times per day.

53. Mr. Medeiros notices hunters entering his property to retrieve

their dogs approximately five times each hunting season since he has

owned the property, but more unauthorized entries likely occur without

notice.

54. Three specific instances stand out among these regular

invasions of the Medeiros Property:

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 55. First, on or about November 24, 2021, Mr. Medeiros witnessed

a hunter and his son, identified by their apparel, enter his property

without permission or solicitation, and retrieve their hunting dog near

the Medeiros home.

56. Mr. Medeiros confronted the pair as they were walking to

their vehicle to leave after collecting the dog and the hunter confirmed

that he was indeed a member of the local Diamond Hill Hunt Club.

57. Second, during the 2017 or 2018 deer-hunting season,

Mr. Medeiros confronted a pair of hunters who had entered his property

from nearby woods, past conspicuously posted “No Trespassing” signs, to

retrieve a hunting dog.

58. The hunters were headed straight for his cattle pasture where

the cattle had been bedded down for the night.

59. Not being able to eject them from his property, with the words

of Lieutenant Naff in his mind, Mr. Medeiros directed them around his

cattle pasture to retrieve the dog through a path that would not result in

the spooking of his cattle.

60. Third, on or about December 11, 2021, Mr. Medeiros received

a scheduled delivery of five head of cattle, including two bulls and three

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steers that was unreasonably interrupted due to hunting dogs running

loose on the Medeiros Property.

61. For approximately two hours, hunting dogs were running

amidst the cattle pasture, disturbing the cattle grazing there and

preventing Mr. Medeiros from having the newly delivered cattle

unloaded from their trailer and introduced to the existing herd.

62. In the end, Mr. Medeiros was forced to leave the cattle trailer

in the field with the newly acquired bulls and steers until the dogs were

gone.

63. Attempting to shoo the dogs away from the cattle pasture and

attempt to capture them so that the new cattle could be released required

pulling staff from the sawmill operation at the Medeiros Property to deal

with the nuisance.

64. Over the years, Mr. Medeiros has suffered losses by hunting

dogs in the form of dead chickens, injured cattle, and disruptions to his

family life and business operations.

The Tovar Property

65. The Tovar Property has been subject to repeated invasions by

hunters and their dogs acting under color of lawful authority according

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to Va. Code § 18.2-136 since Mr. Tovar acquired the property, including

as recently as Virginia’s past deer-hunting season.

66. During the 2020-2021 deer-hunting season, between the

months of November and January, two hunting dogs entered the Tovar

Property.

67. The dogs were identifiable as hunting dogs by their location-

tracking collars.

68. The dogs entered the horse pasture on the Tovar Property,

spooking the horses.

69. The dogs proceeded to the family home where two hunters

wearing orange hats collected them from the property.

70. When confronted about keeping their dogs off the property,

one of them suggested to Mr. Tovar that he ought to fence his property if

he didn’t want hunters and their dogs traversing it and spooking his

horses.

71. Fortunately, no one was in the horse pasture or riding ring

while the horses became spooked by the dogs.

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 The Blue Wing Property

72. The Blue Wing Property has been subject to repeated

invasions by hunters and their dogs acting under color of lawful authority

according to Va. Code § 18.2-136 since Blue Wing acquired the property,

including as recently as Virginia’s past deer-hunting season.

73. Hunters or their dogs running freely on the Blue Wing

Property have disrupted hunts, cookouts, and other activities on the

leased hunting property, presenting a safety threat and burden.

74. It has been a common practice of hunters that are not parties

to any lease contract with Mr. Pierce or Blue Wing LLC to release their

dogs on neighboring properties or the neighboring right-of-way fronting

the Blue Wing Property, and then to follow and retrieve the animals on

the Blue Wing Property, both in vehicles and on foot.

75. As a consequence of retrieving their dogs, hunters have driven

deep ruts in the right-of-way fronting the Blue Wing Property as well as

in the property’s private drive(s).

76. Hunters have likewise pulled the posts from gates barring

ingress and egress on the Blue Wing Property in the course of retrieving

their dogs.

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 77. When confronted about being present on the Blue Wing

Property with their dogs outside deer season, hunters have claimed to be

hunting coyotes, but their dogs are observed freely chasing the deer on

the property that Blue Wing’s lessees pay for the privilege to hunt.

78. Mr. Pierce and Blue Wing LLC have lost clients as a result of

the disruptive nature of dogs running freely across the Blue Wing

Property.

79. The hunting dogs have become such a nuisance on the Blue

Wing Property that Mr. Pierce has installed a kennel to house dogs that

can be captured and kept awaiting retrieval by their owners.

80. Whenever a hunter requests permission from Mr. Pierce to

retrieve his or her dog, Mr. Pierce has granted it. Nonetheless, hunters

continue to invade the Blue Wing Property without seeking permission

to enter.

The Commonwealth’s Guidance regarding the Right to

Retrieve Law has been inconsistent, leaving the rights
and obligations of property owners and hunters unclear

81. A published opinion of the Virginia Attorney General and at

least one ruling without a published opinion by a Virginia Circuit Court

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have interpreted the Right to Retrieve Law to operate as merely an

exception to criminal liability.

82. A 1964 Virginia Attorney General opinion states that the law

does not effect a taking because it simply excepts certain “trespassers

[from] criminal prosecution” while the confining statement “expressly

reserves this civil remedy [for trespass] to the landowner.” Opinions of

the Attorney General and Report to the Governor of Virginia 143 (1964).

This was before that confining statement was excised from the law by the

General Assembly. See 1988 Va. Acts 764, Va. Code § 18.2-136 (“Right of

fox, coon, bear and deer hunters to go on lands of another[.]”).

83. In 2011, the Supreme Court of Virginia affirmed a Virginia

Circuit Court ruling without opinion rejecting a claim that the Right to

Retrieve Law effects an uncompensated taking of property in violation of

the Commonwealth and Federal Constitutions. A petition for writ of

certiorari was thereafter denied. Polin v. Virginia, 566 U.S. 938 (2012).

84. As noted above, a previous codification of the Right to Retrieve

Law contained a confining statement specifying that it not “be construed

to affect in any way the civil rights of a landowner as against trespassers

against his property.” 1946 Va. Acts 575-76 (“An Act to amend and re-

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enact Section 49, as amended, of the Game, Inland Fish and Dog Code of

Virginia, relating to hunting, fishing or trapping on the property of

another”). The separation of this language from the Right to Retrieve

Law, and its ultimate deletion by the General Assembly from the Virginia

Code, demonstrates that landowners no longer possess the civil remedy

to eject hunters who enter private property without permission under

color of the Right to Retrieve Law.

85. This understanding is bolstered by the experiences of

Plaintiffs in their interactions with hunters who claim the privilege to

enter their properties without permission.

86. Likewise, the present position of the Department is in

conformity with this construction. In 2016, the Department published A

Report on Deer Hunting with Dogs, in which it claimed that hunters “can

lawfully retrieve dogs even when access has been expressly denied by the

landowners.” Id. at 3.

87. Published opinions of the Virginia Attorney General

subsequent to the 1964 opinion discussed above reflect a similar position.

For example, a 1988 opinion states that the Right to Retrieve Law

“authorizes these hunters, in the appropriate season, to follow their dogs

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onto private or posted lands[.]” 1987-88 Va. Op. Att’y Gen. 261, 1988 WL

408961, at *2. A 1999 opinion describes the law as “provid[ing] that fox

hunters engaged in a chase that originated on permitted land may follow

their dogs onto prohibited land.” 1999 Va. Op. Att’y Gen. 109, 1999 WL

463381, at *3.

88. Whether the Right to Retrieve Law works as an exception to

criminal liability or as a civil access privilege in the style of an easement

is a matter of great public importance primed for declaratory review,

since the practical effect of the law has been nonenforcement of Plaintiffs’

rights to exclude hunters and hunting dogs from their properties.

LEGAL CLAIM

The Right to Retrieve Law takes Plaintiffs’ right to exclude

hunters from their properties without just compensation

89. Plaintiffs reallege, adopt, and incorporate by reference the

foregoing paragraphs as though fully set forth herein.

90. The Right to Retrieve Law takes Plaintiffs’ property without

compensation for a public use in violation of Article I, § 11 of the Virginia

Constitution and the Fourteenth and Fifth Amendments to the United

States Constitution.

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 91. Article I, § 11 of the Virginia Constitution provides “[t]hat the

General Assembly shall pass no law whereby private property, the right

to which is fundamental, shall be damaged or taken except for public

use,” and “[n]o private property shall be damaged or taken for public use

without just compensation to the owner thereof.”

92. The Fifth Amendment to the United States Constitution

provides likewise that “private property [shall not] be taken for public

use, without just compensation” and is incorporated against the

Commonwealth of Virginia through the Fourteenth Amendment. U.S.

Const. amend. V; Chicago, Burlington & Quincy R.R. Co. v. City of

Chicago, 166 U.S. 226 (1897).

93. Plaintiffs maintain fundamental private property interests in

their rights to exclusive ownership of their respective properties

described in this Petition, Cedar Point Nursery v. Hassid, 141 S. Ct. 2063,

2072 (2021) (quoting Loretto v. Teleprompter Manhattan CATV Corp.,

458 U.S. 419, 435 (1982)) (“The right to exclude is ‘one of the most

treasured’ rights of property ownership.”).

94. The Right to Retrieve Law “appropriates a right to physically

invade [Plaintiffs’] property[,]” Cedar Point, 141 S. Ct. at 2074, for the

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benefit of hunters and their dogs, thus effecting a physical taking per se

for a public use within the meaning of Lucas v. South Carolina Coastal

Council, 505 U.S. 1003 (1992), and Cedar Point Nursery, 141 S. Ct. 2063.

95. The Department is responsible for the enforcement of the

Right to Retrieve Law, causing substantial damage and diminution in

the value of Plaintiffs’ properties, and is therefore in breach of the implied

contract to pay compensation for takings of private property for the

public’s use. See Kitchen v. City of Newport News, 275 Va. 378, 384 (2008).

PRAYER FOR RELIEF

NOW THEREFORE,

1. Plaintiffs respectfully petition this Court for relief in the form

of:

2. A judgment declaring that the Right to Retrieve Law takes

Plaintiffs’ private property without just compensation within the

meaning of Article I, § 11 of the Virginia Constitution and the Fifth

Amendment to the United States Constitution;

3. Upon such a finding, order the impaneling of a jury, pursuant

to Virginia Code § 8.01-187, to determine just compensation in this case;

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 4. Order the award of all appropriate attorneys’ fees and costs to

Plaintiffs.

Dated: April 12, 2022.

Respectfully submitted,

/s/ Daniel Woislaw

DANIEL WOISLAW
Va. Bar No. 91180
Pacific Legal Foundation
3100 Clarendon Blvd., Suite 610
Arlington, Virginia 22201
Telephone: (202) 888-6881
DWoislaw@pacificlegal.org
Counsel for Plaintiffs

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