The Virginia Defamation Law Blog
Virginia state courts have made it abundantly clear: if you’re going to sue someone for defamation, you’d better know exactly what they said—and be able to plead those words with precision at the outset of the case, without the benefit of the discovery process. In Bennett v. Lundh, a June 2025 opinion from the Court of Appeals of Virginia, the court reinforced this long-standing doctrine in emphatic terms. The opinion doesn’t just affirm the dismissal of a defamation claim with prejudice—it offers a primer on why the “in haec verba” (i.e., verbatim) pleading standard exists, how it works, and what happens when a plaintiff ignores it.
The basic facts of the case go like this: Ian Wesley Bennett and Katerina Lundh were coworkers working under a federal government contract. In August 2022, the two attended a business trip to San Francisco. According to the complaint, an incident occurred after dinner one evening in which Lundh—allegedly intoxicated—bumped into Bennett. He claims to have playfully nudged her, after which she slapped him across the face. Later, he made a comment about her personal history, prompting a second slap. Hours later, at a bar with colleagues, a coworker confronted Bennett, accusing him of grabbing Lundh and threatening to report him. That same accusation was apparently referenced in subsequent disciplinary action and ultimately contributed to Bennett’s removal from the government contract.