second part test (Virginia) · Go Syfert
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second part test in Virginia

13 Virginia opinions name it 2 courts 1972–2025 2 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 (8)

CaseFollowedCited
Kennedy v. Mendoza-Martinezgreen
scotus · 1963 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025This second part of the inquiry utilizes seven non-exhaustive factors articulated in Kennedy v. Mendoza-Martinez, 372 U.S. 144, 168-69 (1963).

11
Artis v. Jonesgreen
vactapp · 2008 · cited in 1 Virginia opinions naming this issue, 2019–2019
1 sentence

2019See Artis v. Jones, 52 Va. App. 356, 363 (2008).

11
Moreau v. Fullergreen
va · 2008 · cited in 1 Virginia opinions naming this issue, 2010–2010
2 sentences

2010See Moreau v. Fuller, 276 Va. 127, 137 , 661 S.E.2d 841, 847 (2008) (“We have repeatedly stated that a court speaks only through its written orders.”); Robinson v. Robinson, 54 Va. App. 87, 93 , 675 S.E.2d 873, 876 (2009) (“It is well established that “‘trial courts speak only through their orders and . . . such orders are presumed to reflect accurately what transpired.”’” (quoting Rose v. Commonwealth, 265 Va. 430 , 435 n.2, 578 S.E.2d 758 , 761 n.2 (2003))).

2010See Moreau v. Fuller, 276 Va. 127, 137 , 661 S.E.2d 841, 847 (2008) (“We have repeatedly stated that a court speaks only through its written orders.”); Robinson v. Robinson, 54 Va. App. 87, 93 , 675 S.E.2d 873, 876 (2009) (“It is well established that “‘trial courts speak only through their orders and . . . such orders are presumed to reflect accurately what transpired.”’” (quoting Rose v. Commonwealth, 265 Va. 430 , 435 n.2, 578 S.E.2d 758 , 761 n.2 (2003))).

11
Robinson v. Robinsongreen
vactapp · 2009 · cited in 1 Virginia opinions naming this issue, 2010–2010
2 sentences

2010See Moreau v. Fuller, 276 Va. 127, 137 , 661 S.E.2d 841, 847 (2008) (“We have repeatedly stated that a court speaks only through its written orders.”); Robinson v. Robinson, 54 Va. App. 87, 93 , 675 S.E.2d 873, 876 (2009) (“It is well established that “‘trial courts speak only through their orders and . . . such orders are presumed to reflect accurately what transpired.”’” (quoting Rose v. Commonwealth, 265 Va. 430 , 435 n.2, 578 S.E.2d 758 , 761 n.2 (2003))).

2010See Moreau v. Fuller, 276 Va. 127, 137 , 661 S.E.2d 841, 847 (2008) (“We have repeatedly stated that a court speaks only through its written orders.”); Robinson v. Robinson, 54 Va. App. 87, 93 , 675 S.E.2d 873, 876 (2009) (“It is well established that “‘trial courts speak only through their orders and . . . such orders are presumed to reflect accurately what transpired.”’” (quoting Rose v. Commonwealth, 265 Va. 430 , 435 n.2, 578 S.E.2d 758 , 761 n.2 (2003))).

11
Wright v. Castlesgreen
va · 1986 · cited in 1 Virginia opinions naming this issue, 1996–1996
2 sentences

1996We have held that four elements must be present before res judicata may be asserted to bar a subsequent proceeding: “(1) identity of the remedies sought; (2) identity of the cause of action; (3) identity of the parties; and (4) identity of the quality of the persons for or against whom the claim is made.” Smith v. Ware, 244 Va. 374, 376 , 421 S.E.2d 444, 445 (1992) (quoting Wright v. Castles, 232 Va. 218, 222 , 349 S.E.2d 125, 128 (1986)).

1996We have held that four elements must be present before res judicata may be asserted to bar a subsequent proceeding: “(1) identity of the remedies sought; (2) identity of the cause of action; (3) identity of the parties; and (4) identity of the quality of the persons for or against whom the claim is made.” Smith v. Ware, 244 Va. 374, 376 , 421 S.E.2d 444, 445 (1992) (quoting Wright v. Castles, 232 Va. 218, 222 , 349 S.E.2d 125, 128 (1986)).

11
Lee v. Virginia Employment Commissiongreen
vactapp · 1985 · cited in 1 Virginia opinions naming this issue, 1996–1996
2 sentences

1996Gardner's conduct does not rise to a level sufficient to satisfy the second part of the analysis. "[A]n employee, who for some reason, becomes dissatisfied with his work, must first - 2 - pursue every available option open to him whereby he might alleviate or correct the condition of which he complains before relinquishing his employment." Lee v. Virginia Employment Comm'n, 1 Va. App. 82, 85 , 335 S.E.2d 104, 106 (1985).

1996Gardner's conduct does not rise to a level sufficient to satisfy the second part of the analysis. "[A]n employee, who for some reason, becomes dissatisfied with his work, must first - 2 - pursue every available option open to him whereby he might alleviate or correct the condition of which he complains before relinquishing his employment." Lee v. Virginia Employment Comm'n, 1 Va. App. 82, 85 , 335 S.E.2d 104, 106 (1985).

11
Smith v. Waregreen
va · 1992 · cited in 1 Virginia opinions naming this issue, 1996–1996
2 sentences

1996We have held that four elements must be present before res judicata may be asserted to bar a subsequent proceeding: “(1) identity of the remedies sought; (2) identity of the cause of action; (3) identity of the parties; and (4) identity of the quality of the persons for or against whom the claim is made.” Smith v. Ware, 244 Va. 374, 376 , 421 S.E.2d 444, 445 (1992) (quoting Wright v. Castles, 232 Va. 218, 222 , 349 S.E.2d 125, 128 (1986)).

1996We have held that four elements must be present before res judicata may be asserted to bar a subsequent proceeding: “(1) identity of the remedies sought; (2) identity of the cause of action; (3) identity of the parties; and (4) identity of the quality of the persons for or against whom the claim is made.” Smith v. Ware, 244 Va. 374, 376 , 421 S.E.2d 444, 445 (1992) (quoting Wright v. Castles, 232 Va. 218, 222 , 349 S.E.2d 125, 128 (1986)).

11
United States v. Harrisgreen
scotus · 1971 · cited in 1 Virginia opinions naming this issue, 1972–1972
1 sentence

1972See Harris, supra at 583-84 ; United States ex rel.

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 (7)

CaseCitedYears
Neil v. Biggers green
scotus · 1972
2 sentences

2004The second part of the analysis is the determination of "whether under the `totality of the circumstances' the identification was reliable even though the confrontation procedure was suggestive." Id. at 199 , 93 S.Ct. 375 .

2004The second part of the analysis is the determination of "whether under the `totality of the circumstances' the identification was reliable even though the confrontation procedure was suggestive." Id. at 199 , 93 S.Ct. 375 .

22004–2022
Grady v. Corbin red
scotus · 1990
2 sentences

1992Under the second part of the test, a successive prosecution is barred “if, to establish an essential element of an offense charged in that prosecution, the government will prove conduct that constitutes an offense for which the defendant has already been prosecuted.” Grady, 110 S. Ct. at 2087 .

1992Defendant, therefore, must look to the second part of the test, enunciated in Grady v. Corbin, 495 U.S. 508 (1990), to support his contention that the crimes in issue constituted the “same offense.” Grady bars a “subsequent prosecution” if the prosecution seeks to “establish an essential element” of the second crime by proving conduct that constituted an offense for which an accused was previously prosecuted.

21992–1992
Derby v. Derby green
vactapp · 1989
2 sentences

2011Derby, 8 Va. App. at 28 , 378 S.E.2d at 79 (quoting Pomeroy, supra, § 928).

2011Derby, 8 Va. App. at 28 , 378 S.E.2d at 79 (quoting Pomeroy, supra, § 928).

12011–2011
Rose v. Commonwealth green
va · 2003
2 sentences

2010See Moreau v. Fuller, 276 Va. 127, 137 , 661 S.E.2d 841, 847 (2008) (“We have repeatedly stated that a court speaks only through its written orders.”); Robinson v. Robinson, 54 Va. App. 87, 93 , 675 S.E.2d 873, 876 (2009) (“It is well established that “‘trial courts speak only through their orders and . . . such orders are presumed to reflect accurately what transpired.”’” (quoting Rose v. Commonwealth, 265 Va. 430 , 435 n.2, 578 S.E.2d 758 , 761 n.2 (2003))).

2010See Moreau v. Fuller, 276 Va. 127, 137 , 661 S.E.2d 841, 847 (2008) (“We have repeatedly stated that a court speaks only through its written orders.”); Robinson v. Robinson, 54 Va. App. 87, 93 , 675 S.E.2d 873, 876 (2009) (“It is well established that “‘trial courts speak only through their orders and . . . such orders are presumed to reflect accurately what transpired.”’” (quoting Rose v. Commonwealth, 265 Va. 430 , 435 n.2, 578 S.E.2d 758 , 761 n.2 (2003))).

12010–2010
Walsh v. Walsh green
ca1 · 2000
1 sentence

2008Moscona, 50 Va.App. at 255 , 649 S.E.2d at 199 (quoting Walsh, 221 F.3d at 216 ).

12008–2008
Yuri Isidoro Sasson Moscona v. Dana Shenhar green
vactapp · 2007
2 sentences

2008Moscona, 50 Va.App. at 255 , 649 S.E.2d at 199 (quoting Walsh, 221 F.3d at 216 ).

2008Moscona, 50 Va.App. at 255 , 649 S.E.2d at 199 (quoting Walsh, 221 F.3d at 216 ).

12008–2008
FAIRFAX CTY. FIRE & RESCUE SERVICES v. Newman green
va · 1981
2 sentences

2001Applying the second part of the test, the Court rejected the employer’s contention that the presumption was “essentially irrebuttable because the etiology of pulmonary sarcoidosis[, the respiratory ailment from which the claimánt Newman was suffering,] [was] unknown.” Id. at 541 , 281 S.E.2d at 901 .

2001Applying the second part of the test, the Court rejected the employer’s contention that the presumption was “essentially irrebuttable because the etiology of pulmonary sarcoidosis[, the respiratory ailment from which the claimánt Newman was suffering,] [was] unknown.” Id. at 541 , 281 S.E.2d at 901 .

12001–2001

Statutes the citing opinions construe

VA § Va. Code Ann. § 17.1-413 (5)

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

PA 597 (1944–2026) TX 178 (1954–2026) IL 85 (1937–2026) CA 81 (1947–2026) OH 76 (1983–2026) WA 59 (1929–2026) NM 50 (1977–2025) GA 48 (1981–2026) FL 39 (1969–2024) WI 39 (1984–2026) IN 38 (1985–2025) UT 38 (1989–2026) NJ 35 (1988–2025) CT 32 (1965–2024) MA 30 (1975–2024) OR 29 (1978–2022) KS 28 (1997–2025) NY 28 (1985–2023) MI 28 (1968–2022) MS 24 (1969–2023) MN 21 (1986–2024) IA 21 (1984–2025) TN 20 (1914–2026) NC 20 (1988–2020) MT 20 (1960–2016) NH 19 (1973–2024) RI 18 (1984–2014) MD 17 (1988–2025) MO 17 (1934–2023) ID 15 (1975–2025) SD 14 (1975–2015) LA 14 (1941–2023) VA 13 (1972–2025) ME 13 (1987–2021) CO 13 (1973–2026) DC 11 (1982–2024) WY 10 (1988–2018) AL 9 (1976–2016) AZ 9 (1985–2004) WV 8 (1929–2024) HI 8 (1998–2020) AR 8 (1991–2015) KY 6 (1999–2025) ND 6 (1999–2015) VT 6 (1987–2026) NE 6 (1996–2019) DE 6 (1997–2026) OK 5 (1992–2025) AK 5 (1994–2020) NV 5 (1994–2025) SC 4 (2006–2022)

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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