D. Dortch Warriner, 57, who served since 1974 as a judge of the U.S. District Court for the Eastern District of Virginia, died March 17 after a heart attack at his home in Brunswick County, Va.
Judge Warriner, who heard cases in Alexandria as well as in Richmond, was known before his appointment as a leader of the conservative wing of Virginia's Republican party. As a judge, he was described by colleagues as a stern but fair-minded jurist who demanded high standards from lawyers appearing before him and did not hesitate to point out perceived lapses. He was regarded as a strict constructionist.
In several of his notable cases, Judge Warriner appeared skeptical of the federal government's role in regulating activities of state government or private citizens.
In presiding over a lawsuit brought against the Virginia highway department, Judge Warriner accused the Justice Department of trying to force quotas on the road agency. But in 1983 he accepted a settlement calling for "recruitment goals" and "hiring expectations."
In an earlier case, he rejected Justice Department arguments and cleared Virginia of charges that its state police discriminated against blacks in hiring and promotions.
In a case that aroused substantial interest in the Washington area in particular, he dismissed all charges against two officers of a Northern Virginia construction firm accused of violating federal safety regulations in an Annandale trench cave-in that killed two workers in 1978.
Expressing dissatisfaction with the government's presentation, he called the matter "the strangest criminal case I have ever observed."
Judge Warriner also ruled against federal or state authorities in cases that upheld the rights of the migrant workers and prison inmates, among others.
In 1979 he cited three Agriculture Department officials for criminal contempt of court because of a long delay in carrying out a court order to notify migrant workers on the Eastern Shore of their eligibility for food stamps.
In 1978 he ruled that Richmond police had harassed a U.S. Labor Party congressional candidate, and in 1982 he found several state prison officials in contempt of court for failing to protect prisoners from violence at the hands of other prisoners at a state correctional center.
In expressing opposition to a state law making it a crime to divulge information about investigations of sitting judges, Judge Warriner voiced doubt about the constitutionality of the law and said "public scrutiny on the conduct of judges should be encouraged."
Born in Brunswick County, Judge Warriner graduated from the University of North Carolina and from the University of Virginia law school. After Navy service during the Korean War he was a partner in an Emporia, Va., law firm for 17 years before becoming a judge.
In 1965 he was defeated in a bid for state attorney general on a ticket headed by Linwood Holton.
Survivors include his wife and three children.