course defense (Virginia) · Go Syfert
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course defense in Virginia

20 Virginia opinions name it 3 courts 1887–2021 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 (15)

CaseFollowedCited
Taitano v. Commonwealthgreen
vactapp · 1987 · cited in 4 Virginia opinions naming this issue, 1994–2001
2 sentences

2001The reviewing court must "assess the reasonable probability of a different result in 'light of the totality of circumstances and with an awareness of the difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the [nondisclosure].'" Taitano v. Commonwealth, 4 Va. App. 342, 349 , 358 S.E.2d 590, 594 (1987) (citation omitted).

2001The reviewing court must "assess the reasonable probability of a different result in 'light of the totality of circumstances and with an awareness of the difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the [nondisclosure].'" Taitano v. Commonwealth, 4 Va. App. 342, 349 , 358 S.E.2d 590, 594 (1987) (citation omitted).

44
Robinson v. Commonwealthgreen
va · 1986 · cited in 2 Virginia opinions naming this issue, 1987–1990
2 sentences

1987Bagley requires a court to assess the reasonable probability of a different result “in light of the totality of circumstances and with an awareness of the difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the prosecutor’s incomplete response.” Robinson v. Commonwealth, 231 Va. 142, 152 , 341 S.E.2d 159, 165 (1986) (quoting Bagley, 473 U.S. at 683 ).

1987Bagley requires a court to assess the reasonable probability of a different result “in light of the totality of circumstances and with an awareness of the difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the prosecutor’s incomplete response.” Robinson v. Commonwealth, 231 Va. 142, 152 , 341 S.E.2d 159, 165 (1986) (quoting Bagley, 473 U.S. at 683 ).

22
Bowman v. Commonwealthgreen
va · 1994 · cited in 2 Virginia opinions naming this issue, 1995–1997
2 sentences

1997We must look at the totality of the circumstances with an awareness of the "difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the prosecutor's incomplete response" to [his duty to provide] Brady information. 4 Id. (citation omitted).

1995Bowman, 248 Va. at 134 , 445 S.E.2d at 112 (citation omitted).

12
Riggins v. Nevadagreen
scotus · 1992 · cited in 1 Virginia opinions naming this issue, 2021–2021
1 sentence

2021See Cooper, 517 U.S. at 364 (explaining how the consequences of an erroneous determination threaten the fundamental fairness of our criminal justice system).8 7 For example, a defendant’s inability to communicate with counsel impacts his ability to determine his plea and waive privilege or his right to a jury trial, as well as “a myriad of smaller decisions concerning the course of his defense.” Cooper, 517 U.S. at 354 (quoting Riggins, 504 U.S. at 139-40 (Kennedy, J., concurring)). 8 The risks associated with ordering a potentially “unnecessary” competency evaluation are negligible for a defe

11
Cooper v. Oklahomagreen
scotus · 1996 · cited in 1 Virginia opinions naming this issue, 2021–2021
2 sentences

2021See Cooper, 517 U.S. at 364 (explaining how the consequences of an erroneous determination threaten the fundamental fairness of our criminal justice system).8 7 For example, a defendant’s inability to communicate with counsel impacts his ability to determine his plea and waive privilege or his right to a jury trial, as well as “a myriad of smaller decisions concerning the course of his defense.” Cooper, 517 U.S. at 354 (quoting Riggins, 504 U.S. at 139-40 (Kennedy, J., concurring)). 8 The risks associated with ordering a potentially “unnecessary” competency evaluation are negligible for a defe

2021See Cooper, 517 U.S. at 364 (explaining how the consequences of an erroneous determination threaten the fundamental fairness of our criminal justice system).8 7 For example, a defendant’s inability to communicate with counsel impacts his ability to determine his plea and waive privilege or his right to a jury trial, as well as “a myriad of smaller decisions concerning the course of his defense.” Cooper, 517 U.S. at 354 (quoting Riggins, 504 U.S. at 139-40 (Kennedy, J., concurring)). 8 The risks associated with ordering a potentially “unnecessary” competency evaluation are negligible for a defe

11
GTE Sprint Communications Corp. v. AT&T Communications of Virginia, Inc.green
va · 1985 · cited in 1 Virginia opinions naming this issue, 2017–2017
2 sentences

2017Servs., 274 Va. 27, 34 , 645 S.E.2d 261, 265 (2007)); cf. GTE Sprint Commc’ns Corp. of Va. v. AT&T Commc’ns of Va., 230 Va. 295, 306 , 337 S.E.2d 702, 709 (1985) (corporation commission proceeding). “[T]o entitle a party to a reversal” on the ground of refusal of a continuance request, the challenging party must clearly demonstrate that the hearing officer “abused [his] discretion and that injury resulted to the party complaining.” Haugen, 274 Va. at 34 , 645 S.E.2d at 265 (quoting Rosenberger v. Commonwealth, 159 Va. 953, 957 , 166 S.E. 464, 465 (1932)); see Code § 2.2-4020 (giving agency hea

2017Servs., 274 Va. 27, 34 , 645 S.E.2d 261, 265 (2007)); cf. GTE Sprint Commc’ns Corp. of Va. v. AT&T Commc’ns of Va., 230 Va. 295, 306 , 337 S.E.2d 702, 709 (1985) (corporation commission proceeding). “[T]o entitle a party to a reversal” on the ground of refusal of a continuance request, the challenging party must clearly demonstrate that the hearing officer “abused [his] discretion and that injury resulted to the party complaining.” Haugen, 274 Va. at 34 , 645 S.E.2d at 265 (quoting Rosenberger v. Commonwealth, 159 Va. 953, 957 , 166 S.E. 464, 465 (1932)); see Code § 2.2-4020 (giving agency hea

11
Rosenberger v. Commonwealthgreen
va · 1932 · cited in 1 Virginia opinions naming this issue, 2017–2017
2 sentences

2017Servs., 274 Va. 27, 34 , 645 S.E.2d 261, 265 (2007)); cf. GTE Sprint Commc’ns Corp. of Va. v. AT&T Commc’ns of Va., 230 Va. 295, 306 , 337 S.E.2d 702, 709 (1985) (corporation commission proceeding). “[T]o entitle a party to a reversal” on the ground of refusal of a continuance request, the challenging party must clearly demonstrate that the hearing officer “abused [his] discretion and that injury resulted to the party complaining.” Haugen, 274 Va. at 34 , 645 S.E.2d at 265 (quoting Rosenberger v. Commonwealth, 159 Va. 953, 957 , 166 S.E. 464, 465 (1932)); see Code § 2.2-4020 (giving agency hea

2017Servs., 274 Va. 27, 34 , 645 S.E.2d 261, 265 (2007)); cf. GTE Sprint Commc’ns Corp. of Va. v. AT&T Commc’ns of Va., 230 Va. 295, 306 , 337 S.E.2d 702, 709 (1985) (corporation commission proceeding). “[T]o entitle a party to a reversal” on the ground of refusal of a continuance request, the challenging party must clearly demonstrate that the hearing officer “abused [his] discretion and that injury resulted to the party complaining.” Haugen, 274 Va. at 34 , 645 S.E.2d at 265 (quoting Rosenberger v. Commonwealth, 159 Va. 953, 957 , 166 S.E. 464, 465 (1932)); see Code § 2.2-4020 (giving agency hea

11
Haugen v. SHENANDOAH VALLEY SOCIAL SERVICESgreen
va · 2007 · cited in 1 Virginia opinions naming this issue, 2017–2017
2 sentences

2017Servs., 274 Va. 27, 34 , 645 S.E.2d 261, 265 (2007)); cf. GTE Sprint Commc’ns Corp. of Va. v. AT&T Commc’ns of Va., 230 Va. 295, 306 , 337 S.E.2d 702, 709 (1985) (corporation commission proceeding). “[T]o entitle a party to a reversal” on the ground of refusal of a continuance request, the challenging party must clearly demonstrate that the hearing officer “abused [his] discretion and that injury resulted to the party complaining.” Haugen, 274 Va. at 34 , 645 S.E.2d at 265 (quoting Rosenberger v. Commonwealth, 159 Va. 953, 957 , 166 S.E. 464, 465 (1932)); see Code § 2.2-4020 (giving agency hea

2017Servs., 274 Va. 27, 34 , 645 S.E.2d 261, 265 (2007)); cf. GTE Sprint Commc’ns Corp. of Va. v. AT&T Commc’ns of Va., 230 Va. 295, 306 , 337 S.E.2d 702, 709 (1985) (corporation commission proceeding). “[T]o entitle a party to a reversal” on the ground of refusal of a continuance request, the challenging party must clearly demonstrate that the hearing officer “abused [his] discretion and that injury resulted to the party complaining.” Haugen, 274 Va. at 34 , 645 S.E.2d at 265 (quoting Rosenberger v. Commonwealth, 159 Va. 953, 957 , 166 S.E. 464, 465 (1932)); see Code § 2.2-4020 (giving agency hea

11
Parsons v. Commonwealthgreen
va · 1930 · cited in 1 Virginia opinions naming this issue, 2016–2016
2 sentences

2016“No trial is perfect, and error will at times creep in.” Parsons v. Commonwealth, 154 Va. 832, 852 , 152 S.E. 547, 554 (1930).

2016“No trial is perfect, and error will at times creep in.” Parsons v. Commonwealth, 154 Va. 832, 852 , 152 S.E. 547, 554 (1930).

11
Srinivasan v. Srinivasangreen
vactapp · 1990 · cited in 1 Virginia opinions naming this issue, 2016–2016
1 sentence

2016Assuming without deciding that Williamson’s repeating Kekic’s questions to the witness exceeded her statutory authority to “regulate and expedite the course of the hearing” under Code § 2.2-4020, we next examine whether the questions and answers constituted more than mere harmless error. 4 Because the error, if any, was a statutory violation, we turn to Code § 8.01-678, which makes “harmless-error review required in all cases.” Ferguson v. Commonwealth, 240 Va. ix , ix, 396 S.E.2d 675, 675 (1990) (noting in a text parenthetical that “harmless-error review [is] required in all cases”).

11
Stephen M. Epperly v. E.L. Booker, Warden Attorney General of the Commonwealth of Virginiagreen
ca4 · 1993 · cited in 1 Virginia opinions naming this issue, 2002–2002
1 sentence

2002See Epperly v. Booker, 997 F.2d 1 (4th Cir. 1993).

11
Carter v. Gordongreen
vactapp · 1998 · cited in 1 Virginia opinions naming this issue, 2000–2000
2 sentences

2000Our decision of Carter v. Gordon, 28 Va. App. 133, 141 , 502 S.E.2d 697, 701 (1998), also incorrectly states that the Act permits hearsay evidence and, as its sole authority for that proposition, wrongly cites to Code § 9-6.14:12.

2000Our decision of Carter v. Gordon, 28 Va. App. 133, 141 , 502 S.E.2d 697, 701 (1998), also incorrectly states that the Act permits hearsay evidence and, as its sole authority for that proposition, wrongly cites to Code § 9-6.14:12.

11
Williamson v. the Old Brogue, Inc.green
va · 1986 · cited in 1 Virginia opinions naming this issue, 2000–2000
1 sentence

2000See id.

11
Daniel J. McDougall Jr. v. Kenneth R. Dunngreen
ca4 · 1972 · cited in 1 Virginia opinions naming this issue, 1996–1996
1 sentence

1996Most courts have held that statements taken by an insurance adjuster in the normal course of a claim are made during the regular course of the insurer’s business, not in anticipation of a trial, and are therefore discoverable.” Citing, McDougall v. Dunn, 468 F.2d 468, 473 (4th Cir. 1972), 102 F.R.D. 235 at 237 .

11
Currie v. Commonwealthgreen
vactapp · 1990 · cited in 1 Virginia opinions naming this issue, 1994–1994
2 sentences

1994In addition, the court must “assess the reasonable probability of a different result in light of the totality of circumstances and with an awareness of the difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the [nondisclosure].” Taitano, 4 Va. App. at 349, 358 S.E.2d at 594 ; see Currie v. Commonwealth, 10 Va. App. 204, 209-10 , 391 S.E.2d 79, 82-83 (1990).

1994In addition, the court must “assess the reasonable probability of a different result in light of the totality of circumstances and with an awareness of the difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the [nondisclosure].” Taitano, 4 Va. App. at 349, 358 S.E.2d at 594 ; see Currie v. Commonwealth, 10 Va. App. 204, 209-10 , 391 S.E.2d 79, 82-83 (1990).

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 (4)

CaseCitedYears
United States v. Bagley green
scotus · 1985
2 sentences

1991In addition, the possibility that any adverse effect on preparation and presentation of the defendant's case might have occurred must be assessed "in light of the totality of the circumstances and with an awareness of the difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the prosecutor's incomplete response." Bagley, 473 U.S. at 683 , 105 S.Ct. at 3384 .

1991In addition, the possibility that any adverse effect on preparation and presentation of the defendant's case might have occurred must be assessed "in light of the totality of the circumstances and with an awareness of the difficulty of reconstructing in a post-trial proceeding the course that the defense and the trial would have taken had the defense not been misled by the prosecutor's incomplete response." Bagley, 473 U.S. at 683 , 105 S.Ct. at 3384 .

51986–1994
Morris v. Slappy green
scotus · 1983
2 sentences

2017Hearing officers, like circuit courts, “necessarily require a great deal of latitude in scheduling.” Morris v. Slappy, 461 U.S. 1, 11 , 103 S.Ct. 1610, 1616 , 75 L.Ed.2d 610 (1983).

2017Hearing officers, like circuit courts, “necessarily require a great deal of latitude in scheduling.” Morris v. Slappy, 461 U.S. 1, 11 , 103 S.Ct. 1610, 1616 , 75 L.Ed.2d 610 (1983).

12017–2017
State Farm Fire & Casualty Co. v. Perrigan green
vawd · 1984
1 sentence

1996Most courts have held that statements taken by an insurance adjuster in the normal course of a claim are made during the regular course of the insurer’s business, not in anticipation of a trial, and are therefore discoverable.” Citing, McDougall v. Dunn, 468 F.2d 468, 473 (4th Cir. 1972), 102 F.R.D. 235 at 237 .

11996–1996
Snouffer's Adm'r v. Hansbrough green
va · 1884
1 sentence

1887The cases on this subject are numerous, and are perfectly familiar to the profession.” And iu Snouffer’s Adm’r v. Hansbrough, 79 Va. 166 , the court said: “In cases of this character, where there is an utterly irreconcilable conflict between the testimony of the plaintiff and defendant, where the proper solution of the controversy depends upon the credibility of the witnesses, where the cause has been remanded solely with the view to obtain the opinion of the jury as to some paramount fact necessary, to be ascertained before a decree in accordance with the justice of the case and the rights of

11887–1887

Statutes the citing opinions construe

VA § Va. Code Ann. § 17.1-413 (4)

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.

Where else courts name it

CA 150 (1902–2025) NY 128 (1863–2025) IL 92 (1891–2026) PA 69 (1906–2026) TX 66 (1922–2023) OR 52 (1970–2025) MD 47 (1940–2025) WA 46 (1980–2026) CT 42 (1942–2024) FL 36 (1941–2025) NJ 36 (1938–2026) OH 35 (1985–2023) MI 33 (1921–2025) TN 25 (1977–2025) MO 25 (1901–2022) MA 22 (1876–2024) VA 20 (1887–2021) LA 20 (1963–2018) WI 19 (1946–2026) GA 19 (1979–2019) NC 19 (1950–2021) CO 16 (1963–2021) MN 14 (1922–2024) IN 14 (1891–2013) NE 13 (1910–2022) AZ 11 (1971–2024) AL 11 (1937–2004) UT 10 (1951–2026) IA 10 (1862–2023) HI 9 (1979–2022) DC 9 (1959–2011) RI 9 (1928–2018) AK 8 (1975–2023) OK 8 (1896–2006) DE 7 (1954–2020) MT 7 (1976–2021) WV 7 (1949–2019) WY 6 (1987–2017) MS 6 (1956–2024) SD 6 (1910–2019) AR 5 (1928–2001) ME 5 (1989–2017) KY 4 (2002–2026) KS 4 (1915–2021) VT 3 (1969–2016) NM 3 (1999–2025) NH 3 (1982–1995) ND 3 (1985–1998) SC 3 (1964–1992) NV 2 (1994–2020) ID 2 (1986–1993)

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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