I. Introduction

In Ingleside Emergency Group, LLC v. Hollis, Supreme Court of Virginia (Dec. 18, 2025), the Court resolved a pivotal question under the Virginia Whistleblower Protection Act (“VWPA”), Code § 40.1-27.3: when does a whistleblower retaliation claim accrue for purposes of the one‑year statute of limitations?

The case involves Dr. Michele Hollis, an emergency physician contracted through medical staffing companies to work at HCA hospitals. After she raised concerns about allegedly fraudulent billing practices and the handling of federal COVID‑19 relief funds, she was removed from the work schedule and later deemed to have “resigned.” She sued under the VWPA more than one year after she first noticed she had been taken off the schedule, but less than one year after receiving a letter confirming that her clinical privileges were considered relinquished as of March 3, 2021.

The central legal issue was whether the limitations period began when Hollis first suffered a scheduling change adverse to her employment (March 2–3, 2021), or only when the termination became definite or fully realized (April or June 2021). The Court held that under Virginia’s longstanding “slight injury” accrual rule and the text of the VWPA, the cause of action accrues at the time of the employer’s first “prohibited retaliatory action,” even if the employee does not yet know the full extent of the harm or receive an explicit termination notice.

II. Factual and Procedural Background

A. The Parties and Contracts

Appellants Ingleside Emergency Group, LLC (“IEG”) and Kingsford Emergency Group, LLC (“KEG”) are medical staffing companies that contract with physicians who in turn provide clinical services at HCA Healthcare Company facilities.

In November 2018, Dr. Michele Hollis entered into contracts with these staffing entities. After renewals, she executed new “provider agreements” effective for one year from July 6, 2020. Those agreements could be terminated:

• without cause upon 90 days’ written notice; or
• without notice by the staffing company for certain causes.

B. Alleged Protected Activity

In November and December 2020, Hollis raised two categories of concerns:

• She refused to “upcharge” her services and reported to management that she believed such a practice was fraudulent billing.
• She complained, both verbally and by email, that the defendants had intentionally mismanaged federal COVID‑19 relief funds by failing to distribute funds to physicians.

In January 2021, she was told her contracts would not be renewed unless she agreed to a significant rate cut. In later communications, she noted that withholding relief funds while cutting reimbursement “presents a very bad visual for the general public.”

C. The Adverse Employment Events

The following dates and events are crucial for the statute of limitations analysis:

• March 2, 2021: Hollis “noticed that she was not scheduled to work in April.” She contacted Jason Clark, Vice President of Staffing Operations for HCA, to ask why. Clark responded only that “there is a case pending review” and directed her to contact Dr. Ankur Fadia, who did not return her calls or provide additional information.
• June 2, 2021: Hollis received a letter from HCA stating that her “resignation” was “approved” and that her “appointment and clinical privileges have been considered voluntarily relinquished effective 3/3/2021.” (Emphasis added.)

D. The Lawsuit and Plea in Bar

On April 1, 2022, Hollis filed suit in Henrico County Circuit Court against multiple defendants, including IEG and KEG. Relevant here, she asserted a claim under the VWPA for “terminating” her provider agreements in retaliation for:

• her refusal to engage in fraudulent billing; and
• her reporting of misuse or misappropriation of federal funds.

The complaint alleged that, without written notice, defendants “simply stopped scheduling Hollis for work” beginning in April 2021. She characterized the “decision to terminate” as being in breach of her agreements and retaliatory.

1. Demurrer

The defendants demurred, arguing Hollis failed to allege sufficient facts to state a VWPA claim, particularly as to causation between protected activity and retaliatory acts. In opposing the demurrer, Hollis emphasized that the retaliatory adverse action began when, on March 2, 2021, she noticed she had been removed from the schedule. The circuit court overruled the demurrer.

2. Plea in Bar (Statute of Limitations)

Seizing on Hollis’s own description of the March 2 event as the start of the retaliatory action, IEG and KEG filed a plea in bar asserting that the VWPA claim was time‑barred. They argued:

• Under Code § 40.1‑27.3(C), an employee must sue “within one year of the employer’s prohibited retaliatory action.”
• Hollis alleged that her injury began when she noticed on March 2, 2021 that she was removed from the schedule.
• Therefore, her cause of action accrued no later than March 2–3, 2021, more than one year before she filed suit (April 1, 2022).

3. Hollis’s Response to the Plea in Bar

Hollis argued that:

• In Virginia, a cause of action accrues upon the completion of the last act necessary to complete all elements of the claim, i.e., when the “ultimate act” occurs.
• Under the VWPA, relevant harm is “discharge” or action affecting the “terms and conditions of employment,” collectively an “adverse action.”
• No legal harm existed in March 2021 because the employer could have reversed course and put her back on the schedule before April; only when she actually went without pay in April did actionable harm occur.
• Thus, the “ultimate act” completing the cause of action was the failure to place her on the April schedule, causing lost pay and “essentially terminating her employment.”

The circuit court denied the plea in bar and, at the defendants’ request, certified an interlocutory appeal to the Court of Appeals under Code § 8.01‑675.5.

E. The Court of Appeals’ Decision

The Court of Appeals affirmed. It distinguished its own recent decision in Rivera v. Mantech International Corp., 81 Va. App. 170 (2024), where it held that a VWPA claim accrued on the date the employer notified the employee of termination, not the later effective date.

In Hollis’s case, the Court of Appeals emphasized that:

• Hollis was “never explicitly notified” that a “definitive, adverse employment action” was being taken against her.
• Her employer provided no meaningful communication in response to her inquiries.
• Therefore, her March realization that she was off the schedule and the limited communication that followed did not constitute a definitive adverse action analogous to the explicit termination notice in Rivera.

The Supreme Court of Virginia granted an appeal by IEG and KEG and reversed.

III. Summary of the Supreme Court’s Holding

The Supreme Court held that Hollis’s VWPA claim, as pled, was time‑barred because:

• Under Code § 40.1‑27.3(C), a VWPA claim must be brought “within one year of the employer’s prohibited retaliatory action.”
• Virginia’s general rule of accrual is that a cause of action accrues when the plaintiff first sustains any injury, even if slight, as a result of a wrongful act; the statute of limitations is not delayed until the full extent of damages is realized or the wrong is discovered.
• Hollis’s complaint, taken as true, established that a “prohibited retaliatory action” occurred on March 2, 2021, when she was removed from the work schedule, thereby affecting the “terms” and “conditions” of her employment.
• That action—and the injury it caused—triggered the statute of limitations, regardless of when Hollis fully appreciated the retaliatory nature of the action or its ultimate economic impact.
• The June 2, 2021 letter did not constitute a new, separate retaliatory act but merely confirmed the nature and effective date of the March action.

Because Hollis filed suit on April 1, 2022, more than one year after the March 2021 removal from the schedule, her VWPA claim against IEG and KEG was untimely. The Court reversed the Court of Appeals and remanded for further proceedings consistent with this holding.

In doctrinal terms, the Court established (or at least clarified) the following principle:

For claims under the Virginia Whistleblower Protection Act, the cause of action accrues, and the one‑year limitations period begins to run, on the date of the employer’s first “prohibited retaliatory action,” defined to include any retaliatory change to compensation, terms, conditions, location, or privileges of employment. This is so even if the employee has not yet suffered the full extent of damages or received explicit notice that the employment relationship is being definitively terminated.

IV. Precedents and Authorities Cited

A. Plea in Bar and Standard of Review

• Station #2, LLC v. Lynch, 280 Va. 166 (2010): A plea in bar raises a distinct issue of fact which, if proven, bars the plaintiff’s right to recovery; the moving party bears the burden of proof.
• Hilton v. Martin, 275 Va. 176 (2008): Quoted regarding the nature of a plea in bar.
• Massenburg v. City of Petersburg, 298 Va. 212 (2019): When no evidence is taken on the plea in bar, courts consider only the pleadings and treat the complaint’s factual allegations as true.
• Lostrangio v. Laingford, 261 Va. 495 (2001): Cited for the same “pleadings only” approach.
• Kerns v. Wells Fargo Bank, N.A., 296 Va. 146 (2018); Thorsen v. Richmond SPCA, 292 Va. 257 (2016): A denial of a plea in bar raising the statute of limitations presents a question of law reviewed de novo when there is no genuine dispute of material fact.

These cases frame the analytical lens: the Court must assume the complaint’s factual narrative, but it independently determines the legal consequence—here, when the cause of action accrued.

B. General Accrual and Statute of Limitations Doctrine in Virginia

• Street v. Consumers Mining Corp., 185 Va. 561 (1946): Origin of the “slight injury” rule—once any injury, however slight, is sustained as a consequence of a wrongful act and the law affords a remedy, the statute of limitations attaches at once.
• Keller v. Denny, 232 Va. 512 (1987): Stands for the proposition that without injury or damage, a cause of action cannot accrue.
• Shipman v. Kruck, 267 Va. 495 (2004): Reaffirms that “without some injury or damage, a cause of action cannot accrue.” Also emphasizes that changes to long‑standing accrual rules are for the General Assembly, not the judiciary.
• Kiser v. A.W. Chesterton Co., 285 Va. 12 (2013): Synthesizes the rule: the “act itself is regarded as the ground of the action and is not legally severable from its consequence”; the statute begins to run at the time of the wrongful act/injury, not at the time of discovery or later damage.
• Van Dam v. Gay, 280 Va. 457 (2010): Holds that it is immaterial that all damages do not occur at the time of the initial injury; limitations are not tolled by the fact that substantial damages arise later. Difficulty in ascertaining injury is irrelevant to accrual.
• Treatise: Kent Sinclair & Leigh B. Middleditch, Jr., Virginia Civil Procedure § 4.10 (7th ed. 2020): Cited to underscore that Virginia has “generally rejected” the diligence and discovery rule (i.e., accrual does not wait for the plaintiff to know or reasonably should know of the cause of action).

These authorities provided the doctrinal backbone: accrual occurs at the first moment when legally cognizable injury results from the wrongful act, irrespective of discovery or later unfolding damages.

C. Statutory Construction Principles

• HCA Health Services of Virginia, Inc. v. Levin, 260 Va. 215 (2000): If statutory language is clear and unambiguous, courts apply the plain meaning of the words used.

This principle supports reading Code § 40.1‑27.3(C) exactly as written: the one‑year period runs from “the employer’s prohibited retaliatory action,” not from when the employee discovers retaliation or experiences ultimate termination.

D. VWPA‑Specific Authority: Rivera v. Mantech International Corp.

The Court of Appeals’ decision in Rivera, 81 Va. App. 170 (2024), was the only prior published appellate interpretation of the VWPA’s limitations provision. It held that:

• The limitations period begins to run on the date of the employer’s “prohibited retaliatory action,” per the statute’s text.
• In Rivera’s case, the prohibited action was the employer’s decision to eliminate his position, clearly communicated in a letter dated January 14, 2022.
• Thus, the claim accrued on January 14 (when Rivera was notified of the termination decision), not on February 7 (when the termination became effective).

In Ingleside, the Supreme Court endorsed Rivera’s textual approach and extended its logic: notice to the employee is significant only because, in that case, it was the concrete action itself (the communicated termination decision), not because VWPA accrual demands employee awareness.

V. The Court’s Legal Reasoning

A. The Statutory Framework of the Virginia Whistleblower Protection Act

The VWPA prohibits a broad range of retaliatory conduct. Code § 40.1‑27.3(A) provides in relevant part:

“An employer shall not discharge, discipline, threaten, discriminate against, or penalize an employee, or take other retaliatory action regarding an employee’s compensation, terms, conditions, location, or privileges of employment, because the employee [engages in certain protected activities].”

Code § 40.1‑27.3(C) creates a civil cause of action and sets the limitations period:

“A person who alleges a violation of this section may bring a civil action in a court of competent jurisdiction within one year of the employer’s prohibited retaliatory action.”

Two features are crucial:

• The statute enumerates specific forms of retaliation (discharge, discipline, etc.), and includes the broader residual phrase “other retaliatory action regarding” compensation, terms, conditions, location, or privileges of employment.
• The trigger for the one‑year period is explicitly tied to the “employer’s prohibited retaliatory action,” not to when the employee loses income, when the relationship formally ends, or when the employee discovers the retaliatory motive.

B. Applying Virginia’s “Slight Injury” Accrual Rule to VWPA Claims

Relying on Street, Kiser, Shipman, and Van Dam, the Court reiterated Virginia’s general rule:

“As a general rule, where an injury, though slight, is sustained in consequence of the wrongful or negligent act of another and the law affords a remedy therefor the statute of limitations attaches at once.” (Kiser, quoting Street.)

The Court emphasized several corollaries:

• “Without some injury or damage . . . a cause of action cannot accrue.” (Shipman)
• Once slight injury exists, it is “immaterial that all the damages resulting from the injury do not occur at the time of the injury”; later‑developing or substantial damages do not delay accrual. (Van Dam)
• The “act itself is regarded as the ground of the action and is not legally severable from its consequence.” (Kiser)
• Virginia largely rejects a discovery rule; difficulty in discovering injury or cause of action is “irrelevant” to when the statute begins to run.

By invoking this body of law, the Court made clear that employment‑related statutory claims, including VWPA claims, are subject to the same accrual principles as common‑law torts in the absence of an express statutory discovery rule.

C. Why Removal from the Schedule Was a “Prohibited Retaliatory Action”

The Court’s key factual/legal step was to classify the March 2 removal from the work schedule as the actionable “prohibited retaliatory action” that:

• affected Hollis’s “terms” and “conditions” of employment; and
• caused at least a “slight” injury, sufficient to trigger accrual.

The Court reasoned:

• The provider agreements contemplated ongoing scheduling; being scheduled was a core term and condition of Hollis’s engagement.
• On March 2, 2021, Hollis learned that she was not scheduled for April—i.e., that a concrete scheduling decision had been made affecting her ability to work and earn compensation.
• This was not an ambiguous, future possibility; it was a present, deliberate omission from the schedule.

Viewed through the VWPA’s text, omitting a physician from the work schedule plainly qualifies as an “other retaliatory action regarding an employee’s compensation, terms, [or] conditions . . . of employment.” Code § 40.1‑27.3(A).

The Court noted that the removal’s adverse nature was apparent enough to Hollis that she immediately:

• contacted management to demand an explanation; and
• eventually retained counsel to protect her interests.

This demonstrated a real, present injury—not a mere fear of future harm.

D. The Role of Notice, Intent, and Discovery

The Court of Appeals had grounded its decision in the absence of explicit notice that Hollis’s removal from the schedule was a definitive, adverse employment action, analogizing to the clear termination letter in Rivera.

The Supreme Court rejected this approach, emphasizing:

• For accrual, “the act itself is . . . the ground for the action,” not the “time of the damage or discovery.” (Kiser)
• The VWPA does not require “cognizance of a particular intent” or the employer’s communication of that intent as a prerequisite for accrual.
• The statute’s plain language makes the occurrence of the “prohibited retaliatory action” the trigger—not the employee’s awareness that it is retaliatory or adverse.

In a key passage, the Court stated that it was “unnecessary to provide Hollis any more notice of adversity than that apparent in the act of removing her from the work schedule,” because she was sufficiently cognizant of the injury to act on it. Even if she did not yet know that this removal would be treated as a termination, that ignorance did not toll the statute.

The June 2, 2021 termination letter did not reset the clock. It simply “confirmed that the true nature of the earlier act to remove Hollis from the schedule going forward was to effectively terminate her employment.” The injury had already occurred in March; the letter merely clarified its extent.

E. Harmonizing with Rivera and Rejecting a Notice‑Based Accrual Rule

The Court carefully explained the role of notice in Rivera:

• In Rivera, the “prohibited retaliatory action” was the decision to eliminate the employee’s position, and that decision was “clearly communicated” in a letter.
• The letter itself was the wrongful act—it informed Rivera that his position was eliminated; the communication and the action were one and the same.

Thus, Rivera did not establish a broader rule that accrual always awaits explicit notice of adversity. Instead, it applied the VWPA’s text to the facts presented. In Ingleside, the Court extended that logic:

The “prohibited retaliatory action” is the employer’s act (here, removing Hollis from the schedule), whether or not the employer also issues a formal notice of intent to terminate.

The Court of Appeals’ focus on the absence of explicit notice was thus “at odds with the statute and the facts.” The Supreme Court reaffirmed that Virginia does not adopt a discovery or notice‑based accrual regime for VWPA claims absent legislative instruction.

F. Rejecting the “Ultimate Act” and Multiple‑Acts Theories

Hollis attempted to characterize:

• the March 2 removal from the schedule as a preliminary or “less severe” retaliatory event, and
• the effective termination (as of March 3, confirmed in June) as a distinct, later retaliatory act completing the cause of action.

The Court rejected this framing on two grounds:

1. “Ultimate act” theory conflicts with accrual doctrine. Under Kiser and Van Dam, the law does not wait for the “ultimate” or most severe manifestation of harm. The first actionable injury—no matter how slight—starts the clock.
2. The pleadings themselves tied the termination to the March removal. The complaint and Hollis’s appellate brief acknowledged that when she received the June 2 letter, she understood that her employment had effectively been terminated in March. The June letter did not describe a new, discrete adverse act; it backdated and confirmed the earlier action.

The Court expressly noted that Hollis’s position “might have been different” if she had pled two genuinely discrete retaliatory acts—one being the removal from the schedule and another being a subsequent, independent termination decision. But that was not how her complaint was structured:

“Hollis’s complaint makes clear that the June 2021 termination letter only confirmed that the true nature of the earlier act to remove Hollis from the schedule going forward was to effectively terminate her employment.”

As a result, the cause of action accrued when that earlier act occurred, and the later confirmation could not restart the clock.

VI. Complex Concepts Simplified

A. Plea in Bar

A plea in bar is a procedural device in Virginia practice. It allows a defendant to raise a single, potentially dispositive issue—such as the statute of limitations—that, if proven, bars the plaintiff’s right to recover regardless of the claim’s underlying merits.

In this case, the defendants used a plea in bar to argue that even if everything Hollis alleged was true, the VWPA claim was filed too late. Because no evidence was taken and only the pleadings were considered, the Supreme Court treated the complaint’s factual allegations as true and decided the limitations issue as a pure question of law.

B. Interlocutory Appeal

An interlocutory appeal is an appeal taken before the trial court has entered final judgment resolving all claims. Normally, appeals follow a final judgment. However, Code § 8.01‑675.5 allows certified interlocutory appeals in certain circumstances, including when a legal issue (like a statute of limitations question) is potentially case‑dispositive and important to resolve early.

Here, the circuit court certified, and the Court of Appeals accepted, an interlocutory appeal from the denial of the plea in bar as to the VWPA claim, because the issue would determine whether that claim could proceed at all.

C. Accrual vs. Statute of Limitations vs. Discovery Rule

• Accrual is the legal moment when a cause of action “comes into existence”—that is, when all essential elements, including some actual injury, are present.
• The statute of limitations is the time period within which a lawsuit must be filed after accrual. If the plaintiff does not sue within that period, the claim is barred.
• A discovery rule is an alternative accrual doctrine (used in some jurisdictions and statutes) under which limitations run from the date the plaintiff knew or should have known about the injury and its wrongful cause.

Virginia’s default rule, absent statutory modification, is not a discovery rule. Instead, as Ingleside reiterates, limitations run from the first moment of legal injury, even if the plaintiff does not yet know the injury is actionable or fully understand its scope.

D. “Prohibited Retaliatory Action” and “Adverse Employment Action”

In employment law (especially federal law), an “adverse employment action” typically means an employer’s action that materially affects the terms, conditions, or privileges of employment (e.g., termination, demotion, reduction in pay, or significantly negative changes in assignments).

The VWPA uses its own language—“discharge, discipline, threaten, discriminate against, or penalize,” plus “other retaliatory action regarding an employee’s compensation, terms, conditions, location, or privileges of employment.” Collectively, the Court treats these as “prohibited retaliatory actions.”

In Ingleside, the Court confirms that:

• Removing a physician from the schedule, thereby depriving her of work and pay and altering the contractual arrangement, is a “retaliatory action regarding” compensation and terms/conditions of employment.
• It is irrelevant for accrual purposes whether the employee subjectively understands at that moment that this is “termination” or whether the employer labels it as such.

E. Continuing Consequences vs. New Acts

An important practical distinction lies between:

• a single retaliatory act with continuing consequences (e.g., a decision to remove someone from the schedule that continues to affect each paycheck); and
• multiple, discrete retaliatory acts (e.g., removal from the schedule, followed by an independent later demotion or termination).

Under Virginia’s accrual rule as applied in Ingleside, continuing consequences of one act do not restart the statute of limitations. Only genuinely new wrongful acts would potentially generate new claims with new limitation periods. Here, the Court found no such separate act; everything flowed from the March removal.

VII. Impact and Implications

A. Clarifying Accrual for VWPA Claims

Ingleside is the Supreme Court of Virginia’s first detailed treatment of Code § 40.1‑27.3(C). Together with Rivera, it establishes a clear, employer‑friendly accrual rule:

• Trigger: The date of the employer’s first prohibited retaliatory action—not the date of effective termination, not the date of last paycheck, and not the date the employee subjectively realizes retaliation occurred.
• Scope of “action”: Any retaliatory change to compensation, terms, conditions, location, or privileges of employment, including removal from a work schedule.

This reduces uncertainty about the limitations period for VWPA claims but also shortens the practical time window for employees to bring suit.

B. Consequences for Employees and Plaintiffs’ Counsel

For employees and their attorneys, the decision carries significant cautionary lessons:

• Act early. The clock may start running with the first negative employment action—such as removal from a schedule, loss of shifts, or a demotion—even if the employer has not yet uttered the word “termination.”
• Document chronology precisely. Plaintiffs must carefully identify the earliest date on which a retaliatory act affected their compensation or working conditions. Any lawsuit filed more than one year after that date risks dismissal via plea in bar.
• Pleading strategy. If there are multiple distinct adverse actions (for example, an initial reduction in hours followed months later by a separate termination decision), plaintiffs should clearly plead them as discrete retaliatory acts, each with its own factual basis. Otherwise, courts may treat later events as mere confirmation or consequences of the first act.
• Don’t rely on discovery of intent. Plaintiffs cannot postpone filing until they acquire documents, statements, or other evidence proving retaliatory motive; limitations run regardless of when motive is uncovered.

C. Consequences for Employers and Defense Counsel

For employers, staffing entities, and their counsel, Ingleside offers both opportunities and warnings:

• Limitations defenses are strengthened. Employers can more confidently raise statute‑of‑limitations defenses where the first adverse action occurred more than one year before suit, even if formal termination notices were later.
• Scheduling decisions are legally significant. Removing an employee from schedules or shifts can itself be a VWPA “prohibited retaliatory action,” not merely an operational detail.
• Communication strategy. While lack of explicit notice does not delay accrual, unclear or delayed communications may still create other legal or reputational risks. But from a strict limitations standpoint, employers are now on firmer ground arguing that the limitations period runs from the date of the underlying scheduling or assignment decision.

D. Doctrinal Coherence: Integration with Virginia’s Accrual Framework

From a doctrinal perspective, Ingleside reinforces Virginia’s long‑standing resistance to discovery‑based accrual, extending it decisively to modern statutory employment claims like the VWPA. The Court explicitly deferred to the General Assembly for any change:

“It is the role of the General Assembly, not the judiciary, to change a rule of law that has been relied upon by bench and bar for so long.” (Shipman)

Accordingly, unless the VWPA is amended to adopt a discovery rule or some other special accrual provision, courts will continue to apply the “slight injury” rule to whistleblower retaliation suits.

E. Unresolved and Future Issues

While Ingleside answers the core limitations question, it leaves open several nuances:

• What qualifies as a separate “prohibited retaliatory action”? The Court hints that in another case, multiple discrete acts might yield separate accrual dates. Future litigation will likely explore where the line lies between continuing consequences of one act and genuinely new acts (e.g., a later formal termination after an initial unpaid suspension).
• Equitable doctrines. The opinion does not discuss equitable tolling, fraudulent concealment, or other doctrines that might, in rare circumstances, extend or suspend limitations. Their interaction with VWPA claims remains to be clarified.
• Interplay with federal law. The Court of Appeals in Rivera had explicitly declined to rely on federal precedent under statutes such as Title VII or the False Claims Act, which sometimes apply different accrual or limitations rules. The Supreme Court’s approach in Ingleside confirms that Virginia’s rule is largely independent, so practitioners must not assume federal timelines apply.

VIII. Conclusion

Ingleside Emergency Group, LLC v. Hollis stands as a significant precedent in Virginia employment law, firmly establishing that VWPA whistleblower claims accrue at the moment of the employer’s first prohibited retaliatory action, however slight the resulting injury may appear at that time.

By treating the removal of a physician from the work schedule as an immediate, actionable injury affecting the terms and conditions of employment, the Supreme Court applied venerable accrual principles from Street, Kiser, and Van Dam to a modern statutory retaliation context. The employee’s lack of explicit notice or incomplete understanding of the harm’s ultimate scope did not defer accrual; the statute of limitations began to run as soon as Hollis was taken off the schedule.

Practically, the decision compels Virginia whistleblowers and their counsel to act swiftly when any materially adverse action occurs, including scheduling changes or loss of shifts, and to carefully delineate discrete retaliatory acts when they exist. For employers, it clarifies that early adverse decisions may extinguish potential liability after one year and that limitations defenses should focus on the earliest actionable retaliation, not just formal termination events.

In the broader legal context, Ingleside reinforces Virginia’s commitment to a strict, non‑discovery‑based limitations regime and signals that any departure from this tradition in whistleblower law must come from the legislature rather than the courts.