Clifton v. Clifton Cable, 54 Va. App. 536, 680 S.E.2d 351 (2009)
The Virginia Court of Appeals held that claimant’s widow was not entitled to benefits as a result of a vehicular accident in which the claimant was killed. This case is significant in that it affirmed the claimant was not entitled to death presumption even though death occurred within minutes after a lifesaving crew arrived. Further, the Court expanded unexplained accident defense to cases where two vehicles collided in the middle of the road but the cause of the collision is unknown.