Chaffins v. Atl. Coast Pipeline, LLC, 801 S.E.2d 189

Atlantic Coast Pipeline, LLC (ACP), a federally regulated natural gas company, sought to survey private properties in Buckingham County for a proposed interstate pipeline.
ACP mailed requests for permission to inspect; landowners refused, so ACP sent "notice[s] of intent to enter" stating entry would occur "on or after April 27, 2015" under Va. Code § 56-49.01.
Landowners challenged the notices as noncompliant; ACP filed declaratory judgment actions seeking court validation of its right to enter. The circuit court upheld ACP’s notices; landowners appealed.
Key statutory text: § 56-49.01 requires (B) a proposed inspection date and (C) a notice that "set[s] forth the date of the intended entry," each with specified advance timing.
The Supreme Court considered whether "on or after" notices satisfied the statutory requirement for a date of intended entry and whether the appeal was moot after ACP later issued date-certain notices.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a notice that says "on or after [date]" satisfies § 56-49.01(C)’s requirement to "set forth the date of the intended entry"	Landowners: "On or after" is too vague; statute requires dates certain so owners can prepare and be present.	ACP: "Intended" means planned date; practical delays (weather, equipment) make exact certainty unnecessary and re-noticing would be impractical.	Court: Statute requires dates certain. "On or after" is insufficient; notices were ineffective.
Whether the appeal is moot because ACP later issued date-certain notices covering a limited range in July 2016	Landowners: The original notices remain at issue because the circuit court validated them and ACP continues to rely on them.	ACP: Subsequent operative notices render challenge to the originals academic.	Court: Not moot. Original notices remain a live controversy because they were upheld by the circuit court and could still authorize open-ended entry.

Conyers v. Martial Arts World of Richmond, Inc., 273 Va. 96 (statutory interpretation reviewed de novo)
Crown Central Petroleum Corp. v. Hill, 254 Va. 88 (use plain statutory text when unambiguous)
Eberhardt v. Fairfax Cnty. Emples. Ret. Sys. Bd. of Trs., 283 Va. 190 (read statute as a whole to effectuate legislative intent)
Virginia Electric & Power Co. v. Board of County Supervisors, 226 Va. 382 (interpret statute parts consistently and harmoniously)
Commonwealth v. Doe, 278 Va. 223 (avoid literal interpretations that produce absurd results)
Boynton v. Kilgore, 271 Va. 220 (definition of "absurd result" in statutory construction)
Cook v. Commonwealth, 268 Va. 111 (context for "absurd" interpretation)
E.C. v. Dep’t of Juvenile Justice, 283 Va. 522 (mootness and requirement of an actual controversy)
Daily Press, Inc. v. Commonwealth, 285 Va. 447 (courts should not decide abstract legal questions)