Debora Goad v. Eastman Chemical and Ace American Insurance Company, 1027163

Debora Goad (pro se) appealed a Workers’ Compensation Commission decision denying benefits for alleged work-related injuries, finding no compensable accident, untimely notice, no reasonable excuse for delay, and no causal connection.
The deputy commissioner credited testimony (notably Angel Clements) that Goad’s injuries were not caused at work or by coworker Debra Hodge; the Commission affirmed.
On appeal, Goad’s opening brief purported to include a “Standard of Review” and an argument section but failed to present legal principles or authorities tied to her assignments of error as required by Rule 5A:20(e).
Goad’s brief contained a short, unsupported assertion that she was “inaccurately denied benefits” and cited statutes rather than developing legal argument or citing controlling case law on review standards.
The Court of Appeals reviewed Virginia precedent about appellate briefing and waiver and concluded Goad’s noncompliance with Rule 5A:20(e) was significant.
Because of the briefing deficiency, the Court exercised discretion to treat the assignments of error as waived and summarily affirmed the Commission’s decision under Rule 5A:27.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did appellant comply with Rule 5A:20(e) briefing requirements?	Goad asserted she was wrongly denied benefits but provided no legal authorities or developed argument.	Appellees relied on the Commission’s factual findings and procedural rules; brief noncompliance warranted no relief.	Goad’s brief failed Rule 5A:20(e); noncompliance was significant and arguments were not considered (waived).
Should the Court review the Commission’s factual credibility findings (causation, witness credibility)?	Goad challenged the Commission’s credibility and causation findings.	Appellees and the Commission relied on credited testimony that injuries were not work-related.	Court did not review merits because arguments were waived due to briefing deficiencies.
Was dismissal or other sanction appropriate for brief defects?	Goad sought reversal of the Commission’s denial of benefits.	Appellees implied dismissal or refusal to consider undeveloped claims was appropriate.	Court summarily affirmed the Commission (exercise of Rule 5A remedies); did not further sanction.
Does pro se status excuse failure to comply with briefing rules?	Goad proceeded pro se and made minimal submissions.	Appellees and precedent: pro se litigants remain bound by rules.	Pro se status does not excuse noncompliance; appellant must follow briefing rules.

Fadness v. Fadness, 52 Va. App. 833 (2008) (unsupported assertions of error do not merit appellate consideration)
Jones v. Commonwealth, 51 Va. App. 730 (2008) (appellant must present error with supporting legal authority)
Ceres Marine Terminals v. Armstrong, 59 Va. App. 694 (2012) (appellant must present error to appellate court with authority)
Atkins v. Commonwealth, 57 Va. App. 2 (2010) (significant failure to follow Rule 5A:20(e) may result in waiver)
Parks v. Parks, 52 Va. App. 663 (2008) (Rule 5A:20(e) requirements and consequences for noncompliance)
Townes v. Commonwealth, 234 Va. 307 (1987) (pro se litigants are bound by rules of procedure and law)
Francis v. Francis, 30 Va. App. 584 (1999) (reinforcing that pro se litigants must comply with court rules)
Jay v. Commonwealth, 275 Va. 510 (2008) (discussing dismissal and other remedies for procedural noncompliance)