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26 Virginia opinions name it 4 courts 1925–2024 5 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.
| Case | Followed | Cited |
|---|---|---|
Chawla v. BurgerBusters, Inc.green2 sentences2012See Chawla v. BurgerBusters, Inc., 255 Va. 616, 623 , 499 S.E.2d 829, 833 (1998), in which the Supreme Court of Virginia noted that as with the waiver of any legal right, the waiver noted in Code § 8.01-384(A) “will be implied only upon clear and unmistakable proof of the intention to waive such right for the essence of waiver is voluntary choice.” The Supreme Court of Virginia later bolstered this principle in King v. Commonwealth, 264 Va. 576 , 570 S.E.2d 863 (2002), holding: The same rationale applies to the circumstances of this case with equal, if not greater, force considering the gravit 2012See Chawla v. BurgerBusters, Inc., 255 Va. 616, 623 , 499 S.E.2d 829, 833 (1998), in which the Supreme Court of Virginia noted that as with the waiver of any legal right, the waiver noted in Code § 8.01-384(A) “will be implied only upon clear and unmistakable proof of the intention to waive such right for the essence of waiver is voluntary choice.” The Supreme Court of Virginia later bolstered this principle in King v. Commonwealth, 264 Va. 576 , 570 S.E.2d 863 (2002), holding: The same rationale applies to the circumstances of this case with equal, if not greater, force considering the gravit | 3 | 4 |
Manchester Oaks Homeowners Ass'n v. Battgreen2 sentences2023See Manchester Oaks, 284 Va. at 420. 2023See Manchester Oaks Homeowners Ass’n, Inc. v. Batt, 284 Va. 409 , 420 (2012) (equality is inherent in the definition of a common area). | 3 | 3 |
Cheng v. Commonwealthgreen2 sentences2020While “a valid waiver will not be presumed simply from the silence of the accused after the warnings are given,” Miranda does not require “a waiver to be in writing or verbally expressed, nor does it preclude the conclusion that a waiver occurred based on the suspect’s course of conduct.” Id. at 259; see Cheng v. Commonwealth, 240 Va. 26, 35 (1990) (“Cheng’s decision to talk with Officer Carter, after having been advised of the Miranda rights, constitutes an implied waiver of those rights.”); see also Eaton v. Commonwealth, 240 Va. 236, 251 (1990) (inferring a waiver of defendant’s right to co 2013While “a valid waiver will not be presumed simply from the silence of the accused after the warnings are given,” Miranda does not require “a waiver to be in writing or verbally expressed, nor does it preclude the conclusion that a waiver occurred based on the suspect’s course of conduct.” Angel, 281 Va. at 259 , 704 S.E.2d at 392 ; see Cheng v. Commonwealth, 240 Va. 26, 35 , 393 S.E.2d 599, 604 (1990) (“Cheng’s decision to talk with Officer Carter, after having been advised of the Miranda rights, constitutes an implied waiver of those rights.”); see also Eaton v. Commonwealth, 240 Va. 236, 251 | 3 | 3 |
Eaton v. Commonwealthgreen2 sentences2020While “a valid waiver will not be presumed simply from the silence of the accused after the warnings are given,” Miranda does not require “a waiver to be in writing or verbally expressed, nor does it preclude the conclusion that a waiver occurred based on the suspect’s course of conduct.” Id. at 259; see Cheng v. Commonwealth, 240 Va. 26, 35 (1990) (“Cheng’s decision to talk with Officer Carter, after having been advised of the Miranda rights, constitutes an implied waiver of those rights.”); see also Eaton v. Commonwealth, 240 Va. 236, 251 (1990) (inferring a waiver of defendant’s right to co 2013While “a valid waiver will not be presumed simply from the silence of the accused after the warnings are given,” Miranda does not require “a waiver to be in writing or verbally expressed, nor does it preclude the conclusion that a waiver occurred based on the suspect’s course of conduct.” Angel, 281 Va. at 259 , 704 S.E.2d at 392 ; see Cheng v. Commonwealth, 240 Va. 26, 35 , 393 S.E.2d 599, 604 (1990) (“Cheng’s decision to talk with Officer Carter, after having been advised of the Miranda rights, constitutes an implied waiver of those rights.”); see also Eaton v. Commonwealth, 240 Va. 236, 251 | 2 | 2 |
Norton v. Commonwealthgreen2 sentences1997See Norton v. Commonwealth, 19 Va.App. 97, 99 , 448 S.E.2d 892, 893 (1994) (recognizing that a defendant may impliedly waive his right to be tried within the statutory period). 1997See Norton v. Commonwealth, 19 Va.App. 97, 99 , 448 S.E.2d 892, 893 (1994) (recognizing that a defendant may impliedly waive his right to be tried within the statutory period). | 2 | 2 |
Harrison v. Commonwealthgreen2 sentences2024Harrison followed the Seventh Circuit’s holding in Bryan v. Warden, Indiana State Reformatory, 820 F.2d 217 (7th Cir. 1987), that “whether a waiver of Miranda is voluntary is a factual determination.” See Harrison, 244 Va. at 581 (citing Bryan, 820 F.2d at 220 ). 2023See id. at 586 (holding that the defendant’s choice to reengage with detectives after asserting his right to silence was an implied waiver); Angel, 281 Va. at 259-60 (holding that the juvenile defendant’s voluntary conversation with officers after signing a Spanish Miranda “waiver of rights form” was a valid waiver). | 1 | 2 |
Angel v. Com.green2 sentences2023See id. at 586 (holding that the defendant’s choice to reengage with detectives after asserting his right to silence was an implied waiver); Angel, 281 Va. at 259-60 (holding that the juvenile defendant’s voluntary conversation with officers after signing a Spanish Miranda “waiver of rights form” was a valid waiver). 2013While “a valid waiver will not be presumed simply from the silence of the accused after the warnings are given,” Miranda does not require “a waiver to be in writing or verbally expressed, nor does it preclude the conclusion that a waiver occurred based on the suspect’s course of conduct.” Angel, 281 Va. at 259 , 704 S.E.2d at 392 ; see Cheng v. Commonwealth, 240 Va. 26, 35 , 393 S.E.2d 599, 604 (1990) (“Cheng’s decision to talk with Officer Carter, after having been advised of the Miranda rights, constitutes an implied waiver of those rights.”); see also Eaton v. Commonwealth, 240 Va. 236, 251 | 1 | 2 |
Baumann v. Capoziogreen2 sentences2006See Baumann v. Capozio, 269 Va. 356, 361 , 611 S.E.2d 597, 597 (2005). 2006See Baumann v. Capozio, 269 Va. 356, 361 , 611 S.E.2d 597, 597 (2005). | 1 | 2 |
United States v. Derrick Myran Frankson, (Two Cases)green2 sentences2006“A defendant’s ‘subsequent willingness to answer questions after acknowledging [his] Miranda rights is sufficient to constitute an implied waiver.’” United States v. Frankson, 83 F.3d 79, 82 (4th Cir. 1996) (quoting United States v. Velasquez, 626 F.2d 314, 320 (3d Cir. 1980)). 2001As the Court of Appeals for the Fourth Circuit explained, “a defendant’s subsequent willingness to answer questions after acknowledging his Miranda rights is sufficient to constitute an implied waiver.” Frankson, 83 F.3d at 82 . | 1 | 2 |
Hudson v. Commonwealthgreen2 sentences2018We now consider whether an implied exception excuses the delay. “[E]xceptions stated in the [speedy trial] statute are not meant to be all-inclusive, and other exceptions of a similar nature are implied.” Hudson v. Commonwealth, 267 Va. 36, 41 , 591 S.E.2d 679, 682 (2004) (citing Stephens, 225 Va. at 230 , 301 S.E.2d at 25 ). “[J]udicially recognized exceptions to the time requirement are permissible as long as they are of a similar nature and have the same rationale as the enumerated exceptions.” Wallace, 65 Va. App. at 93-94 , 774 S.E.2d at 488 (quoting Stephens, 225 Va. at 230 , 301 S.E.2d 2018We now consider whether an implied exception excuses the delay. “[E]xceptions stated in the [speedy trial] statute are not meant to be all-inclusive, and other exceptions of a similar nature are implied.” Hudson v. Commonwealth, 267 Va. 36, 41 , 591 S.E.2d 679, 682 (2004) (citing Stephens, 225 Va. at 230 , 301 S.E.2d at 25 ). “[J]udicially recognized exceptions to the time requirement are permissible as long as they are of a similar nature and have the same rationale as the enumerated exceptions.” Wallace, 65 Va. App. at 93-94 , 774 S.E.2d at 488 (quoting Stephens, 225 Va. at 230 , 301 S.E.2d | 1 | 1 |
Schwartz v. Commonwealthgreen2 sentences2018This Court has stated that “the rationale behind the exceptions . . . is to ‘provide for speedy trial exceptions in circumstances ‘beyond the control of the trial [court] and the parties,’ when delays are warranted to ‘ensure a fair trial to - 11 - both the accused and the Commonwealth.’” Id. at 94, 774 S.E.2d at 489 (quoting Schwartz v. Commonwealth, 45 Va. App. 407, 426 , 611 S.E.2d 631, 641 (2005)). 2018This Court has stated that “the rationale behind the exceptions . . . is to ‘provide for speedy trial exceptions in circumstances ‘beyond the control of the trial [court] and the parties,’ when delays are warranted to ‘ensure a fair trial to - 11 - both the accused and the Commonwealth.’” Id. at 94, 774 S.E.2d at 489 (quoting Schwartz v. Commonwealth, 45 Va. App. 407, 426 , 611 S.E.2d 631, 641 (2005)). | 1 | 1 |
Stephens v. Commonwealthgreen2 sentences2018We now consider whether an implied exception excuses the delay. “[E]xceptions stated in the [speedy trial] statute are not meant to be all-inclusive, and other exceptions of a similar nature are implied.” Hudson v. Commonwealth, 267 Va. 36, 41 , 591 S.E.2d 679, 682 (2004) (citing Stephens, 225 Va. at 230 , 301 S.E.2d at 25 ). “[J]udicially recognized exceptions to the time requirement are permissible as long as they are of a similar nature and have the same rationale as the enumerated exceptions.” Wallace, 65 Va. App. at 93-94 , 774 S.E.2d at 488 (quoting Stephens, 225 Va. at 230 , 301 S.E.2d 2018We now consider whether an implied exception excuses the delay. “[E]xceptions stated in the [speedy trial] statute are not meant to be all-inclusive, and other exceptions of a similar nature are implied.” Hudson v. Commonwealth, 267 Va. 36, 41 , 591 S.E.2d 679, 682 (2004) (citing Stephens, 225 Va. at 230 , 301 S.E.2d at 25 ). “[J]udicially recognized exceptions to the time requirement are permissible as long as they are of a similar nature and have the same rationale as the enumerated exceptions.” Wallace, 65 Va. App. at 93-94 , 774 S.E.2d at 488 (quoting Stephens, 225 Va. at 230 , 301 S.E.2d | 1 | 1 |
CERES MARINE TERMINALS v. Armstronggreen2 sentences2017See Ceres Marine Terminals, 59 Va.App. at 703 , 722 S.E.2d at 306 . *419 F. Retroactive Reimbursement Finally, NNSB argues that it presented clear and convincing evidence of an implied waiver by Wardell which estops Wardell from recovering written-off account balances in this case. 2017See Ceres Marine Terminals, 59 Va.App. at 703 , 722 S.E.2d at 306 . *419 F. Retroactive Reimbursement Finally, NNSB argues that it presented clear and convincing evidence of an implied waiver by Wardell which estops Wardell from recovering written-off account balances in this case. | 1 | 1 |
King v. Commonwealthgreen2 sentences2012See Chawla v. BurgerBusters, Inc., 255 Va. 616, 623 , 499 S.E.2d 829, 833 (1998), in which the Supreme Court of Virginia noted that as with the waiver of any legal right, the waiver noted in Code § 8.01-384(A) “will be implied only upon clear and unmistakable proof of the intention to waive such right for the essence of waiver is voluntary choice.” The Supreme Court of Virginia later bolstered this principle in King v. Commonwealth, 264 Va. 576 , 570 S.E.2d 863 (2002), holding: The same rationale applies to the circumstances of this case with equal, if not greater, force considering the gravit 2012See Chawla v. BurgerBusters, Inc., 255 Va. 616, 623 , 499 S.E.2d 829, 833 (1998), in which the Supreme Court of Virginia noted that as with the waiver of any legal right, the waiver noted in Code § 8.01-384(A) “will be implied only upon clear and unmistakable proof of the intention to waive such right for the essence of waiver is voluntary choice.” The Supreme Court of Virginia later bolstered this principle in King v. Commonwealth, 264 Va. 576 , 570 S.E.2d 863 (2002), holding: The same rationale applies to the circumstances of this case with equal, if not greater, force considering the gravit | 1 | 1 |
United States v. Velasquez, Cecilia, in No. 79-2737, Velasquez, Pauline, in No. 79-2777green2 sentences2006“A defendant’s ‘subsequent willingness to answer questions after acknowledging [his] Miranda rights is sufficient to constitute an implied waiver.’” United States v. Frankson, 83 F.3d 79, 82 (4th Cir. 1996) (quoting United States v. Velasquez, 626 F.2d 314, 320 (3d Cir. 1980)). 2006“A defendant’s ‘subsequent willingness to answer questions after acknowledging [his] Miranda rights is sufficient to constitute an implied waiver.’” United States v. Frankson, 83 F.3d 79, 82 (4th Cir. 1996) (quoting United States v. Velasquez, 626 F.2d 314, 320 (3d Cir. 1980)). | 1 | 1 |
Michigan v. Mosleygreen2 sentences2004As the United States Supreme Court has emphasized, once an accused has “ ‘expressed his own view that he is not competent to deal with the authorities without legal advice, a later decision at the authorities’ insistence to make a statement without counsel’s presence may properly be viewed with skepticism.’ ” Arizona v. Roberson, 486 U.S. 675, 681 , 108 S.Ct. 2093, 2098 , 100 L.Ed.2d 704 (1988) (quoting Mosley, 423 U.S. at 110, n. 2 , 96 S.Ct. at 329, n. 2 ). 2004As the United States Supreme Court has emphasized, once an accused has “ ‘expressed his own view that he is not competent to deal with the authorities without legal advice, a later decision at the authorities’ insistence to make a statement without counsel’s presence may properly be viewed with skepticism.’ ” Arizona v. Roberson, 486 U.S. 675, 681 , 108 S.Ct. 2093, 2098 , 100 L.Ed.2d 704 (1988) (quoting Mosley, 423 U.S. at 110, n. 2 , 96 S.Ct. at 329, n. 2 ). | 1 | 1 |
Allen v. Commonwealthgreen2 sentences2002In Allen , we recognized that “ ‘[wjaiver is ordinarily an intentional relinquishment or abandonment of a known right or privilege,’ and with respect to fundamental constitutional rights, ‘courts indulge every reasonable presumption against waiver.’ ” 252 Va. at 111 , 472 S.E.2d at 280 (citations omitted). 2002In Allen , we recognized that “ ‘[wjaiver is ordinarily an intentional relinquishment or abandonment of a known right or privilege,’ and with respect to fundamental constitutional rights, ‘courts indulge every reasonable presumption against waiver.’ ” 252 Va. at 111 , 472 S.E.2d at 280 (citations omitted). | 1 | 1 |
Colorado v. Springgreen2 sentences2001See Colorado v. Spring, 479 U.S. 564, 574 , 93 L. 2001See Colorado v. Spring, 479 U.S. 564, 574 , 93 L. | 1 | 1 |
Creteau v. Phoenix Assurance Co. of New Yorkgreen2 sentences1971Creteau v. Phoenix Assurance Co., 202 Va. 641, 644 , 119 S.E.2d 336, 339 (1961); Roenke v. Va. Farm Bureau Ins. 1971Creteau v. Phoenix Assurance Co., 202 Va. 641, 644 , 119 S.E.2d 336, 339 (1961); Roenke v. Va. Farm Bureau Ins. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Howard v. Com.
green
2 sentences2019The Court of Appeals held that a court-ordered continuance is considered an implied exception to the time periods under the speedy trial act under Howard v. Commonwealth , 281 Va. 455 , 461, 706 S.E.2d 885 (2011). 2019The Court of Appeals held that a court-ordered continuance is considered an implied exception to the time periods under the speedy trial act under Howard v. Commonwealth , 281 Va. 455 , 461, 706 S.E.2d 885 (2011). | 2 | 2018–2019 |
Martin R. Bryan v. Warden, Indiana State Reformatory
green
2 sentences2024Harrison followed the Seventh Circuit’s holding in Bryan v. Warden, Indiana State Reformatory, 820 F.2d 217 (7th Cir. 1987), that “whether a waiver of Miranda is voluntary is a factual determination.” See Harrison, 244 Va. at 581 (citing Bryan, 820 F.2d at 220 ). 2024Harrison followed the Seventh Circuit’s holding in Bryan v. Warden, Indiana State Reformatory, 820 F.2d 217 (7th Cir. 1987), that “whether a waiver of Miranda is voluntary is a factual determination.” See Harrison, 244 Va. at 581 (citing Bryan, 820 F.2d at 220 ). | 1 | 2024–2024 |
Andrew Wallace v. Commonwealth of Virginia
green
2 sentences2018We now consider whether an implied exception excuses the delay. “[E]xceptions stated in the [speedy trial] statute are not meant to be all-inclusive, and other exceptions of a similar nature are implied.” Hudson v. Commonwealth, 267 Va. 36, 41 , 591 S.E.2d 679, 682 (2004) (citing Stephens, 225 Va. at 230 , 301 S.E.2d at 25 ). “[J]udicially recognized exceptions to the time requirement are permissible as long as they are of a similar nature and have the same rationale as the enumerated exceptions.” Wallace, 65 Va. App. at 93-94 , 774 S.E.2d at 488 (quoting Stephens, 225 Va. at 230 , 301 S.E.2d 2018We now consider whether an implied exception excuses the delay. “[E]xceptions stated in the [speedy trial] statute are not meant to be all-inclusive, and other exceptions of a similar nature are implied.” Hudson v. Commonwealth, 267 Va. 36, 41 , 591 S.E.2d 679, 682 (2004) (citing Stephens, 225 Va. at 230 , 301 S.E.2d at 25 ). “[J]udicially recognized exceptions to the time requirement are permissible as long as they are of a similar nature and have the same rationale as the enumerated exceptions.” Wallace, 65 Va. App. at 93-94 , 774 S.E.2d at 488 (quoting Stephens, 225 Va. at 230 , 301 S.E.2d | 1 | 2018–2018 |
Stockbridge v. Gemini Air Cargo, Inc.
green
2 sentences2017NNSB cites Stockbridge, 269 Va. at 620-21 , 611 S.E.2d at 606 , for the proposition that the Virginia Supreme Court deemed a corporation to have knowledge of its affairs upon receipt of a stockholder’s put notice, and based on that case this Court must conclude that because Wardell had actual notice of the Longshore Act payments, delaying three years to bring this claim bars recovery. 2017NNSB cites Stockbridge, 269 Va. at 620-21 , 611 S.E.2d at 606 , for the proposition that the Virginia Supreme Court deemed a corporation to have knowledge of its affairs upon receipt of a stockholder’s put notice, and based on that case this Court must conclude that because Wardell had actual notice of the Longshore Act payments, delaying three years to bring this claim bars recovery. | 1 | 2017–2017 |
Gravely v. Deeds
green
2 sentences2011Gravely, 185 Va. at 665 , 40 S.E.2d at 176 . 2011Gravely, 185 Va. at 665 , 40 S.E.2d at 176 . | 1 | 2011–2011 |
Pysell v. Keck
green
2 sentences2005We recognize that this Court has used different legal phrases to describe the burden of proof necessary to establish an implied waiver-"the party relying on a waiver has the burden to prove the essentials of the waiver by clear, precise and unequivocal evidence" and "waiver of a legal right will be implied only upon clear and unmistakable proof of the intention to waive such right." Moreover, we stated in a case involving an express waiver that "[a] waiver must be express, or, if it is to be implied, it must be established by clear and convincing evidence." Pysell v. Keck, 263 Va. 457 , 460, 5 2005We recognize that this Court has used different legal phrases to describe the burden of proof necessary to establish an implied waiver-"the party relying on a waiver has the burden to prove the essentials of the waiver by clear, precise and unequivocal evidence" and "waiver of a legal right will be implied only upon clear and unmistakable proof of the intention to waive such right." Moreover, we stated in a case involving an express waiver that "[a] waiver must be express, or, if it is to be implied, it must be established by clear and convincing evidence." Pysell v. Keck, 263 Va. 457 , 460, 5 | 1 | 2005–2005 |
Fox v. Deese
green
2 sentences2005We have stated in several cases that "[w]aiver of a legal right will be implied only upon clear and unmistakable proof of the intention to waive such right for the essence of waiver is voluntary choice." Chawla, 255 Va. at 623 , 499 S.E.2d at 833 ; Weidman, 241 Va. at 45 , 400 S.E.2d at 167 ; Fox, 234 Va. at 426 , 362 S.E.2d at 707 ; Coleman v. Nationwide Life Ins. 2005We have stated in several cases that "[w]aiver of a legal right will be implied only upon clear and unmistakable proof of the intention to waive such right for the essence of waiver is voluntary choice." Chawla, 255 Va. at 623 , 499 S.E.2d at 833 ; Weidman, 241 Va. at 45 , 400 S.E.2d at 167 ; Fox, 234 Va. at 426 , 362 S.E.2d at 707 ; Coleman v. Nationwide Life Ins. | 1 | 2005–2005 |
Weidman v. Babcock
green
2 sentences2005We have stated in several cases that "[w]aiver of a legal right will be implied only upon clear and unmistakable proof of the intention to waive such right for the essence of waiver is voluntary choice." Chawla, 255 Va. at 623 , 499 S.E.2d at 833 ; Weidman, 241 Va. at 45 , 400 S.E.2d at 167 ; Fox, 234 Va. at 426 , 362 S.E.2d at 707 ; Coleman v. Nationwide Life Ins. 2005We have stated in several cases that "[w]aiver of a legal right will be implied only upon clear and unmistakable proof of the intention to waive such right for the essence of waiver is voluntary choice." Chawla, 255 Va. at 623 , 499 S.E.2d at 833 ; Weidman, 241 Va. at 45 , 400 S.E.2d at 167 ; Fox, 234 Va. at 426 , 362 S.E.2d at 707 ; Coleman v. Nationwide Life Ins. | 1 | 2005–2005 |
Arizona v. Roberson
green
2 sentences2004As the United States Supreme Court has emphasized, once an accused has “ ‘expressed his own view that he is not competent to deal with the authorities without legal advice, a later decision at the authorities’ insistence to make a statement without counsel’s presence may properly be viewed with skepticism.’ ” Arizona v. Roberson, 486 U.S. 675, 681 , 108 S.Ct. 2093, 2098 , 100 L.Ed.2d 704 (1988) (quoting Mosley, 423 U.S. at 110, n. 2 , 96 S.Ct. at 329, n. 2 ). 2004As the United States Supreme Court has emphasized, once an accused has “ ‘expressed his own view that he is not competent to deal with the authorities without legal advice, a later decision at the authorities’ insistence to make a statement without counsel’s presence may properly be viewed with skepticism.’ ” Arizona v. Roberson, 486 U.S. 675, 681 , 108 S.Ct. 2093, 2098 , 100 L.Ed.2d 704 (1988) (quoting Mosley, 423 U.S. at 110, n. 2 , 96 S.Ct. at 329, n. 2 ). | 1 | 2004–2004 |
Wade v. Hunter
green
2 sentences2002In determining whether, and to what extent, the failure to make an express objection to a declaration of a mistrial should act as an implied consent, the focus must be on the consequence that the implied consent is also an implied waiver of the defendant’s “valued right to have his trial completed by a particular tribunal.” Wade, 336 U.S. at 689 . 2002In determining whether, and to what extent, the failure to make an express objection to a declaration of a mistrial should act as an implied consent, the focus must be on the consequence that the implied consent is also an implied waiver of the defendant's "valued right to have his trial completed by a particular tribunal." Wade, 336 U.S. at 689 , 69 S.Ct. 834 . | 1 | 2002–2002 |
Commonwealth v. Edwards
green
2 sentences1994Commonwealth v. Edwards, 235 Va. 499 , 370 S.E.2d 296 (1988). 1994Commonwealth v. Edwards, 235 Va. 499 , 370 S.E.2d 296 (1988). | 1 | 1994–1994 |
| Scott v. Albemarle Horse Show Ass'n green | 1 | 1950–1950 |
| First National Bank of Louisa v. Anderson neutral | 1 | 1925–1925 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.