Berry analysis (Virginia) · Go Syfert
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Berry analysis in Virginia

5 Virginia opinions name it 1 courts 1995–2022 1 in the last five years

The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (14)

CaseFollowedCited
Bell v. Commonwealthgreen
vactapp · 1996 · cited in 2 Virginia opinions naming this issue, 2004–2010
2 sentences

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

22
Coram v. Commonwealthgreen
vactapp · 1987 · cited in 2 Virginia opinions naming this issue, 2004–2010
2 sentences

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

22
Phoung v. Commonwealthgreen
vactapp · 1992 · cited in 2 Virginia opinions naming this issue, 2004–2010
2 sentences

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

22
Hoke v. Commonwealthgreen
va · 1989 · cited in 2 Virginia opinions naming this issue, 2004–2010
2 sentences

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

22
Brown v. Commonwealthgreen
va · 1985 · cited in 2 Virginia opinions naming this issue, 2004–2010
2 sentences

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

22
Cardwell v. Commonwealthgreen
va · 1994 · cited in 2 Virginia opinions naming this issue, 2004–2010
2 sentences

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

22
Powell v. Commonwealthgreen
va · 2001 · cited in 2 Virginia opinions naming this issue, 2004–2010
2 sentences

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

2010See, e.g., Powell v. Commonwealth, 261 Va. 512, 541 , 552 S.E.2d 344, 360-61 (2001) (upholding conviction for abduction as more than necessary to accomplish rape where the defendant ordered [the] victim to go to a more secluded part of her home and bound and detained her for a lengthy *722 period of time); Cardwell v. Commonwealth, 248 Va. 501, 511 , 450 S.E.2d 146, 153 (1994) (upholding conviction for abduction because it was “greater than the restraint intrinsic in a robbery” where [the] defendant transported [the] victim away from the robbery scene, which robbery was already complete, and m

22
In re: Woodleygreen
va · 2015 · cited in 1 Virginia opinions naming this issue, 2020–2020
1 sentence

2020Homeowners Ass’n, Inc., 291 Va. 269, 277 (2016) (quoting In re: Woodley, 290 Va. 482, 491 (2015)).

11
Tvardek v. Powhatan Vill. Homeowners Ass'n, Inc.green
va · 2016 · cited in 1 Virginia opinions naming this issue, 2020–2020
1 sentence

2020Homeowners Ass’n, Inc., 291 Va. 269, 277 (2016) (quoting In re: Woodley, 290 Va. 482, 491 (2015)).

11
State v. Stouffergreen
md · 1998 · cited in 1 Virginia opinions naming this issue, 2004–2004
2 sentences

2004Id.; see also United States v. Howard, 918 F.2d 1529, 1536 (11th Cir.1990) (adopting the Berry analysis); People v. Smith, 91 Ill.App.3d 523 , 47 Ill.Dec. 1 , 414 N.E.2d 1117, 1122 (1980) (same); cf. Stouffer, 721 A.2d at 215 (declining to adopt any specific test, but nonetheless applying the factors *495 delineated in Berry); State v. Farmer, 191 W.Va. 372 , 445 S.E.2d 759, 764 (1994) (stating that it is appropriate to examine certain factors substantially similar to those delineated in Berry).

2004Id.; see also United States v. Howard, 918 F.2d 1529, 1536 (11th Cir.1990) (adopting the Berry analysis); People v. Smith, 91 Ill.App.3d 523 , 47 Ill.Dec. 1 , 414 N.E.2d 1117, 1122 (1980) (same); cf. Stouffer, 721 A.2d at 215 (declining to adopt any specific test, but nonetheless applying the factors *495 delineated in Berry); State v. Farmer, 191 W.Va. 372 , 445 S.E.2d 759, 764 (1994) (stating that it is appropriate to examine certain factors substantially similar to those delineated in Berry).

11
United States v. Jeffrey David Howard, Ricky Leroy Stanley, Derrick Smith, Samuel J. Cooper, Jr.green
ca11 · 1991 · cited in 1 Virginia opinions naming this issue, 2004–2004
2 sentences

2004Id.; see also United States v. Howard, 918 F.2d 1529, 1536 (11th Cir.1990) (adopting the Berry analysis); People v. Smith, 91 Ill.App.3d 523 , 47 Ill.Dec. 1 , 414 N.E.2d 1117, 1122 (1980) (same); cf. Stouffer, 721 A.2d at 215 (declining to adopt any specific test, but nonetheless applying the factors *495 delineated in Berry); State v. Farmer, 191 W.Va. 372 , 445 S.E.2d 759, 764 (1994) (stating that it is appropriate to examine certain factors substantially similar to those delineated in Berry).

2004Id.; see also United States v. Howard, 918 F.2d 1529, 1536 (11th Cir.1990) (adopting the Berry analysis); People v. Smith, 91 Ill.App.3d 523 , 47 Ill.Dec. 1 , 414 N.E.2d 1117, 1122 (1980) (same); cf. Stouffer, 721 A.2d at 215 (declining to adopt any specific test, but nonetheless applying the factors *495 delineated in Berry); State v. Farmer, 191 W.Va. 372 , 445 S.E.2d 759, 764 (1994) (stating that it is appropriate to examine certain factors substantially similar to those delineated in Berry).

11
People v. Smithgreen
illappct · 1980 · cited in 1 Virginia opinions naming this issue, 2004–2004
2 sentences

2004Id.; see also United States v. Howard, 918 F.2d 1529, 1536 (11th Cir.1990) (adopting the Berry analysis); People v. Smith, 91 Ill.App.3d 523 , 47 Ill.Dec. 1 , 414 N.E.2d 1117, 1122 (1980) (same); cf. Stouffer, 721 A.2d at 215 (declining to adopt any specific test, but nonetheless applying the factors *495 delineated in Berry); State v. Farmer, 191 W.Va. 372 , 445 S.E.2d 759, 764 (1994) (stating that it is appropriate to examine certain factors substantially similar to those delineated in Berry).

2004Id.; see also United States v. Howard, 918 F.2d 1529, 1536 (11th Cir.1990) (adopting the Berry analysis); People v. Smith, 91 Ill.App.3d 523 , 47 Ill.Dec. 1 , 414 N.E.2d 1117, 1122 (1980) (same); cf. Stouffer, 721 A.2d at 215 (declining to adopt any specific test, but nonetheless applying the factors *495 delineated in Berry); State v. Farmer, 191 W.Va. 372 , 445 S.E.2d 759, 764 (1994) (stating that it is appropriate to examine certain factors substantially similar to those delineated in Berry).

11
State v. Farmergreen
wva · 1994 · cited in 1 Virginia opinions naming this issue, 2004–2004
2 sentences

2004Id.; see also United States v. Howard, 918 F.2d 1529, 1536 (11th Cir.1990) (adopting the Berry analysis); People v. Smith, 91 Ill.App.3d 523 , 47 Ill.Dec. 1 , 414 N.E.2d 1117, 1122 (1980) (same); cf. Stouffer, 721 A.2d at 215 (declining to adopt any specific test, but nonetheless applying the factors *495 delineated in Berry); State v. Farmer, 191 W.Va. 372 , 445 S.E.2d 759, 764 (1994) (stating that it is appropriate to examine certain factors substantially similar to those delineated in Berry).

2004Id.; see also United States v. Howard, 918 F.2d 1529, 1536 (11th Cir.1990) (adopting the Berry analysis); People v. Smith, 91 Ill.App.3d 523 , 47 Ill.Dec. 1 , 414 N.E.2d 1117, 1122 (1980) (same); cf. Stouffer, 721 A.2d at 215 (declining to adopt any specific test, but nonetheless applying the factors *495 delineated in Berry); State v. Farmer, 191 W.Va. 372 , 445 S.E.2d 759, 764 (1994) (stating that it is appropriate to examine certain factors substantially similar to those delineated in Berry).

11
Wells v. Com., Dept. of Transp.green
vactapp · 1993 · cited in 1 Virginia opinions naming this issue, 1995–1995
2 sentences

1995Wells v. Commonwealth, Dep't of Transp., 15 Va. App. 561, 565 , 425 S.E.2d 536, 538 (1993).

1995Wells v. Commonwealth, Dep't of Transp., 15 Va. App. 561, 565 , 425 S.E.2d 536, 538 (1993).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (1)

CaseCitedYears
Toms v. Hanover Department of Social Services green
vactapp · 2005
1 sentence

2022Accordingly, his hearsay objection has been waived.8 8 As for Berry’s challenge of the foster-care goal of adoption, “[o]ur decision to affirm the termination order necessarily subsumes this aspect of his appeal because a preponderance-of-the-evidence standard governs judicial modifications of foster care plans.” Toms, 46 Va. App. at 265 n.3. -9- CONCLUSION Considering the totality of the evidence in the light most favorable to the Department, the circuit court did not err in terminating Berry’s parental rights under either Code § 16.1-283(B) or (C)(2).

12022–2022

Where else courts name it

UT 20 (1992–2024) LA 20 (1988–2006) MS 14 (1992–2023) CA 11 (2000–2026) GA 7 (1979–2022) PA 6 (1992–2025) TX 5 (1986–2025) OH 5 (1999–2025) VA 5 (1995–2022) WA 5 (1979–2017) NJ 4 (1990–2023) AL 4 (1989–2023) ID 3 (1986–1991) VI 3 (2013–2017) WY 3 (1984–2004) MD 3 (1993–2011) MO 3 (1959–2020) MA 3 (2011–2012) DC 2 (2001–2024) MT 2 (2005–2010) IN 2 (1998–2015) OK 2 (2003–2005) KS 2 (1999–2003) ME 2 (1998–2020) AK 2 (2013–2016) NY 2 (1972–1989) KY 2 (2023–2023) AZ 2 (1991–2011)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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