exigency exception (Virginia) · Go Syfert
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exigency exception in Virginia

5 Virginia opinions name it 1 courts 2003–2024 3 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 (6)

CaseFollowedCited
Missouri v. McNeelygreen
scotus · 2013 · cited in 3 Virginia opinions naming this issue, 2017–2024
2 sentences

2024Finally, “the exigency analysis requires a review of ‘the totality of the circumstances.’” Id. (quoting Missouri v. McNeely, 569 U.S. 141, 149 (2013)).

2021Additionally, the list is not exhaustive, and the exigency analysis requires a review of “the totality of circumstances.” McNeely, 569 U.S. at 149 .

13
Verez v. Commonwealthgreen
va · 1985 · cited in 1 Virginia opinions naming this issue, 2023–2023
1 sentence

2023Lange, 141 S. Ct. at 2018 (quoting Birchfield v. North Dakota, 579 U.S. 438, 457 (2016)). -6- In Verez v. Commonwealth, 230 Va. 405, 410-11 (1985), the Supreme Court enumerated factors to be considered in determining the presence of exigent circumstances: (1) the degree of urgency involved and the time required to get a warrant; (2) the officers’ reasonable belief that contraband is about to be removed or destroyed; (3) the possibility of danger to others, including police officers left to guard the site; (4) information that the possessors of the contraband are aware that the police may be on

11
Birchfield v. N. Dakota. William Robert Bernardgreen
scotus · 2016 · cited in 1 Virginia opinions naming this issue, 2023–2023
1 sentence

2023Lange, 141 S. Ct. at 2018 (quoting Birchfield v. North Dakota, 579 U.S. 438, 457 (2016)). -6- In Verez v. Commonwealth, 230 Va. 405, 410-11 (1985), the Supreme Court enumerated factors to be considered in determining the presence of exigent circumstances: (1) the degree of urgency involved and the time required to get a warrant; (2) the officers’ reasonable belief that contraband is about to be removed or destroyed; (3) the possibility of danger to others, including police officers left to guard the site; (4) information that the possessors of the contraband are aware that the police may be on

11
Hill v. Com.green
vactapp · 1994 · cited in 1 Virginia opinions naming this issue, 2021–2021
1 sentence

2021Washington, 60 Va. App. at 438 (noting that, consistent with the Fourth Amendment, officers “are not required to possess either the gift of prophecy or the infallible wisdom that comes with hindsight” (quoting Hill v. Commonwealth, 18 Va. App. 1, 3 (1994))).

11
Jerry Lee Washington v. Commonwealth of Virginiagreen
vactapp · 2012 · cited in 1 Virginia opinions naming this issue, 2021–2021
1 sentence

2021Washington, 60 Va. App. at 438 (noting that, consistent with the Fourth Amendment, officers “are not required to possess either the gift of prophecy or the infallible wisdom that comes with hindsight” (quoting Hill v. Commonwealth, 18 Va. App. 1, 3 (1994))).

11
Jackson v. Commonwealthgreen
vactapp · 1996 · cited in 1 Virginia opinions naming this issue, 2003–2003
2 sentences

2003Given the clarity of Dyson on this point, the exigent circumstances dicta in McCary (as well as our cases repeating it, see, e.g., Jackson - 6 - v. Commonwealth, 22 Va. App. 347, 355 , 470 S.E.2d 138, 143 (1996)), have no continuing precedential weight. 2 In his suppression motion, Rogers also asserted that the warrantless search of his van violated Virginia constitutional law prohibiting "illegal searches and seizures." We again disagree.

2003Given the clarity of Dyson on this point, the exigent circumstances dicta in McCary (as well as our cases repeating it, see, e.g., Jackson - 6 - v. Commonwealth, 22 Va. App. 347, 355 , 470 S.E.2d 138, 143 (1996)), have no continuing precedential weight. 2 In his suppression motion, Rogers also asserted that the warrantless search of his van violated Virginia constitutional law prohibiting "illegal searches and seizures." We again disagree.

11

Distinguished, questioned or overruled (0)

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

Where else courts name it

TX 75 (2001–2025) PA 28 (1922–2024) OH 26 (2006–2026) MA 25 (1975–2025) NJ 20 (2006–2025) FL 18 (1975–2025) OR 17 (1955–2022) IN 17 (2002–2025) CA 15 (1922–2026) IA 14 (1981–2021) ID 14 (1971–2023) MN 12 (2000–2017) NY 12 (1851–2026) WI 11 (1976–2022) IL 10 (1980–2023) MD 9 (1994–2019) NM 8 (2004–2025) NV 6 (1997–2018) DC 6 (1991–2017) VA 5 (2003–2024) SC 5 (2014–2020) CO 4 (1984–2026) CT 4 (1980–2025) MO 4 (1981–2010) UT 4 (1990–2025) MS 4 (2004–2024) NH 4 (1985–2018) LA 4 (2000–2018) MI 4 (1912–2020) SD 3 (2001–2014) RI 3 (1984–2002) AZ 3 (2003–2018) NC 3 (2015–2017) WA 3 (2007–2016) ND 3 (2015–2026) TN 3 (2008–2016) ME 2 (1969–1983) GA 2 (1988–1999) NE 2 (2015–2017) HI 2 (2017–2021) AL 2 (2006–2006) VI 2 (2012–2015) KS 2 (2011–2020) DE 2 (1980–2019)

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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