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

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.