The Supreme Court of Virginia has never been asked to determine a third party's contribution rights where his negligence has combined with that of an employer to cause personal injury to an employee covered by the Virginia Workmen's Compensation Act [hereinafter referred to as the Act]. Although the question is a novel one in Virginia, courts in other jurisdictions have coped with the problem and have arrived at diverse solutions. At the outset, a brief review of the Act and of the Virginia contribution statute seems appropriate.
Robert I. Stevenson,
Effect of Virginia Workmen's Compensation Act upon the Right of a Third-Party Tortfeasor to Obtain Contribution from an Employer Whose Concurrent Negligence Caused Employee's Death or Injury,
U. Rich. L. Rev.
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