Luis Rivera v. Mantech International Corporation, 902 S.E.2d 120

Luis Rivera, employed by ManTech International Corporation, was stationed at the U.S. Embassy in Baghdad as a technician.
Rivera participated in an investigation into alleged illegal document forgery, reporting refusal to forge documents when directed by a supervisor.
On January 14, 2022, ManTech informed Rivera in writing of his termination due to "contract reduction," with his employment ending on February 7, 2022, and revoked his security clearance effective immediately.
Rivera remained on payroll until February 7, 2022, when his employment formally ended and he was potentially eligible for rehire.
Rivera filed a lawsuit on February 7, 2023, alleging retaliation in violation of the Virginia Whistleblower Protection Law (VWPL).
The Circuit Court dismissed Rivera’s claim as untimely, holding the statute of limitations began with the January 14, 2022 notice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the VWPL one-year statute of limitations accrue?	Accrual should be the effective date of termination (Feb. 7, 2022), as potential for continued employment existed until then.	Accrual begins with notice of termination and revocation of security clearance (Jan. 14, 2022), the date of the retaliatory action.	The statute begins at notice of termination (Jan. 14, 2022); Rivera’s complaint is untimely.

Massenburg v. City of Petersburg, 298 Va. 212 (explains plea in bar framework and limitations burden)
Kerns v. Wells Fargo Bank, N.A., 296 Va. 146 (accrual of cause of action upon injury, even if damages occur later)
Kiser v. A.W. Chesterton Co., 285 Va. 12 (statute of limitations starts upon any injury, no matter how slight)
First Virginia Bank-Colonial v. Baker, 225 Va. 72 (right of action requires injury; accrual is upon injury)
Lo v. Burke, 249 Va. 311 (injury triggers accrual of cause of action)
Board of Supervisors v. Thompson Assoc., 240 Va. 133 (action accrues when plaintiff knows of basis for claim)