"The general rule in Virginia is that a single act of physical abuse normally cannot constitute grounds for divorce. …
“The single act may, however, constitute a ground for divorce if the act is ‘so severe and atrocious as to endanger life, if it indicates an intention to do serious bodily harm, if it causes reasonable apprehension of serious danger in the future, or if the precedent or attendant circumstances show that the acts are likely to be repeated.’ ...
"The continuing and escalating behavior ... culminated in physical abuse as corroborated by the description of the event, the injuries as indicated in the photograph, the issuance of a protective order and a conviction for assault and battery."
Davis v. Davis, Record No.0190-20-4, Oct. 27, 2020. Va. Court of Appeals, Unpublished.