Dawson v. Hotchkiss
In Dawson v. Hotchkiss, 160 Va. 577, 169 S.E. 564 (1933), the Court conducted an extensive factual analysis to determine whether the attorney had apparent authority to enter an agreement on behalf of the client. Dawson, 160 Va. at 582, 169 S.E. at 566.
The Supreme Court concluded that, in "light of all the facts and circumstances shown by the evidence," the attorney did not have "apparent authority to make a binding contract for the client." Id. at 586, 169 S.E. at 567.
The Supreme Court thus affirmed the legal theory of apparent authority in the context of an attorney/client relationship, but found the evidence failed to support a finding of apparent authority in that case.