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Here, a declaratory judgment is an inappropriate form of relief because Adams’ “alleged
wrongs have already been suffered.” Hylton Enters., Inc., 216 Va. at 585. Ms. Hall has already
denied Adams’ applications for the reasons stated in her letter. While Code § 8.01-184 gives
courts the power to adjudicate rights in controversies involving the “interpretation of . . .
municipal ordinances,” declaratory relief is unavailable where the rights in question have “fully
matured.” Hylton Enters., Inc., 216 Va. at 585; see Bishop, 211 Va. at 421 (dismissing
appellees’ petition for declaratory judgment where “the various claims and rights asserted had all
accrued and matured, and . . . the wrongs had been suffered, when their petition for a declaratory
judgment was filed”). Moreover, Adams has an alternate “mode of proceeding” here, one of
which it has already availed itself: it has appealed to the BZA and has petitioned the circuit court
for relief. See Bishop, 211 Va. at 421. It is thus not entitled to a declaratory judgment.
C. Adams Is Not Entitled to a Writ of Mandamus
Adams asked the circuit court to issue a writ of mandamus “commanding [appellees] to
certify on VDOT Form OA-105A that the location of the outdoor advertising signs described in
the [permit applications] comply with the City’s then-existing zoning ordinance.” Mandamus
relief is similarly inappropriate here.
“Mandamus is an extraordinary remedy that may be used to compel a public official to
perform a purely ministerial duty imposed by law. The use of the remedy is limited.” Umstattd
v. Centex Homes, G.P., 274 Va. 541, 545 (2007) (citation omitted). “It is not available where the
applicant has an adequate remedy at law.” Id. In Gannon v. State Corp. Commission, 243 Va.
480 (1992), for instance, the plaintiff filed a Virginia Freedom of Information Act (VFOIA)
request, seeking records in the possession of the State Corporation Commission. Id. at 481. The
Commission denied his request, stating that it was not subject to VFOIA. Id. The plaintiff
thereafter filed a petition for a writ of mandamus to compel the Commission to produce the Jump to an indexed page (13 of 13)