White motion (Virginia) · Go Syfert
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White motion in Virginia

11 Virginia opinions name it 2 courts 1981–2025 4 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 (10)

CaseFollowedCited
McLean v. Commonwealthgreen
vactapp · 2000 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., White, 293 Va. at 422-24 (finding that any error in denying White’s motion to suppress evidence was harmless as a matter of law because the remaining evidence, including evidence found on and around White’s person, demonstrated beyond a reasonable doubt that a rational juror would have found him guilty without the disputed evidence and the disputed evidence played a limited role at trial); McLean v. Commonwealth, 32 Va. App. 200, 216-17 (2000) (same); Bass v. Commonwealth, 31 Va. App. 373, 391-92 (2000) (same).

11
Bass v. Commonwealthgreen
vactapp · 2000 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., White, 293 Va. at 422-24 (finding that any error in denying White’s motion to suppress evidence was harmless as a matter of law because the remaining evidence, including evidence found on and around White’s person, demonstrated beyond a reasonable doubt that a rational juror would have found him guilty without the disputed evidence and the disputed evidence played a limited role at trial); McLean v. Commonwealth, 32 Va. App. 200, 216-17 (2000) (same); Bass v. Commonwealth, 31 Va. App. 373, 391-92 (2000) (same).

11
Commonwealth v. Whitegreen
va · 2017 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., White, 293 Va. at 422-24 (finding that any error in denying White’s motion to suppress evidence was harmless as a matter of law because the remaining evidence, including evidence found on and around White’s person, demonstrated beyond a reasonable doubt that a rational juror would have found him guilty without the disputed evidence and the disputed evidence played a limited role at trial); McLean v. Commonwealth, 32 Va. App. 200, 216-17 (2000) (same); Bass v. Commonwealth, 31 Va. App. 373, 391-92 (2000) (same).

11
Conyers v. MARTIAL ARTS WORLD OF RICHMONDgreen
va · 2007 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025But “an issue of statutory interpretation is a pure question of law which we review de novo.” Id. (quoting Conyers v. Martial Arts World of Richmond, Inc., 273 Va. 96, 104 (2007)).

11
Rowe v. Com.green
va · 2009 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025The approbate and reprobate doctrine “applies when the error the defendant complains of on appeal is ‘obviously the result of his own strategy and actions at trial.’” Commonwealth v. Holman, 303 Va. 62 , 72 (2024) (quoting Rowe v. Commonwealth, 277 Va. 495, 502 (2009)).

11
Andrew McQuay Jacobs v. Commonwealth of Virginiagreen
vactapp · 2013 · cited in 1 Virginia opinions naming this issue, 2025–2025
2 sentences

2025White’s motion to reconsider,” White argues that the “Condition 6 and Condition 8 violations arose from a single course of conduct,” and the circuit court “erred by treating them separately for purposes of sentencing.”3 He maintains all the violations arose from the same course of conduct, which was his “downward spiral after his relapse.” In an appeal of a probation revocation, the circuit court’s “findings of fact and judgment will not be reversed unless there is a clear showing of abuse of discretion.” Green v. Commonwealth, 75 Va. App. 69 , 76 (2022) (quoting Jacobs v. Commonwealth, 61 Va.

2025But “an issue of statutory interpretation is a pure question of law which we review de novo.” Id. (quoting Conyers v. Martial Arts World of Richmond, Inc., 273 Va. 96, 104 (2007)).

11
Commonwealth v. Ealygreen
vactapp · 1991 · cited in 1 Virginia opinions naming this issue, 2021–2021
1 sentence

2021Ultimately, questions of exigency will depend on the particular facts of the specific case with small changes in those facts greatly affecting the analysis. - 21 - White’s motion to suppress was well founded and that all of the evidence discovered in the apartment should be suppressed as “fruit of the poisonous tree.” See generally Commonwealth v. Ealy, 12 Va. App. 744, 754 (1991).

11
Ian Christian Carlson v. Commonwealth of Virginiagreen
vactapp · 2019 · cited in 1 Virginia opinions naming this issue, 2021–2021
1 sentence

2021Although there are doctrines that permit evidence discovered in an illegal search to remain admissible, see Carlson v. Commonwealth, 69 Va. App. 749, 759 (2019), none are applicable here.

11
Mason v. Commonwealthgreen
va · 2016 · cited in 1 Virginia opinions naming this issue, 2021–2021
1 sentence

2021Standard of review As an appellant “challenging the trial court’s denial of his motion to suppress, [White] ‘bears the burden of establishing that reversible error occurred.’” Saal v. Commonwealth, 72 Va. App. 413 , 421 (2020) (quoting Mason v. Commonwealth, 291 Va. 362, 367 (2016)).

11
Commonwealth v. Harleygreen
va · 1998 · cited in 1 Virginia opinions naming this issue, 2017–2017
2 sentences

2017Reversed in part, vacated in part, and final judgment. 6 See Commonwealth v. Harley, 256 Va. 216, 219 , 504 S.E.2d 852, 853 (1998) (holding that the question whether a trial court erred is “rendered moot” by any “further ruling that the error . . . was harmless”). 13

2017Reversed in part, vacated in part, and final judgment. 6 See Commonwealth v. Harley, 256 Va. 216, 219 , 504 S.E.2d 852, 853 (1998) (holding that the question whether a trial court erred is “rendered moot” by any “further ruling that the error . . . was harmless”). 13

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 (6)

CaseCitedYears
Lashant Leonardo White v. Commonwealth of Virginia green
vactapp · 2016
2 sentences

2017Id. at 366-67 , 785 S.E.2d at 256 .

2017Id. at 366-67 , 785 S.E.2d at 256 .

22017–2017
Santen v. Tuthill green
va · 2003
2 sentences

2019We likewise considered the original wording of an assignment of error in Santen and did not address an added phrase to the assignment of error on brief, noting that "an appellant may not change the wording of an assignment of error." 265 Va. at 497 n.4, 578 S.E.2d 788 .

2019We likewise considered the original wording of an assignment of error in Santen and did not address an added phrase to the assignment of error on brief, noting that "an appellant may not change the wording of an assignment of error." 265 Va. at 497 n.4, 578 S.E.2d 788 .

12019–2019
Cantwell v. Commonwealth green
vactapp · 1986
2 sentences

2016“Without anything in a court order or elsewhere in the record to show that a defendant agreed to or concurred in the delay of his trial . . . the delay must be attributed to the Commonwealth.” Cantwell, 2 Va. App. at 611 , 347 S.E.2d at 526 .

2016“Without anything in a court order or elsewhere in the record to show that a defendant agreed to or concurred in the delay of his trial . . . the delay must be attributed to the Commonwealth.” Cantwell, 2 Va. App. at 611 , 347 S.E.2d at 526 .

12016–2016
Massie v. Firmstone green
va · 1922
2 sentences

2006In its motion in limine, the Commonwealth asserted that Dr. Brock's report did not support an insanity defense, that expert testimony is a "necessary predicate to asserting an insanity defense," and that the defendant cannot "rise above his own evidence" citing to Massie v. Firmstone, 134 Va. 450 , 114 S.E. 652 (1922). 1 Opposing the Commonwealth's motion, defense counsel argued that Dr. Brock's report could be "helpful" in establishing the existence of a mental disease or defect, and proffered additional testimony from lay witnesses to support White's defense on this issue.

2006In its motion in limine, the Commonwealth asserted that Dr. Brock's report did not support an insanity defense, that expert testimony is a "necessary predicate to asserting an insanity defense," and that the defendant cannot "rise above his own evidence" citing to Massie v. Firmstone, 134 Va. 450 , 114 S.E. 652 (1922). 1 Opposing the Commonwealth's motion, defense counsel argued that Dr. Brock's report could be "helpful" in establishing the existence of a mental disease or defect, and proffered additional testimony from lay witnesses to support White's defense on this issue.

12006–2006
Florida v. JL green
scotus · 2000
2 sentences

2001Id.

2001Id.

12001–2001
Weddle, Administratrix v. Draper green
va · 1963
2 sentences

1981At the conclusion of the plaintiffs evidence, the trial court sustained White’s motion to strike the plaintiffs evidence on the ground that the plaintiff had failed to produce evidence overcoming White’s testimony he was in his proper lane of travel and that Weddle, Administratrix v. Draper, 204 Va. 319 , 130 S.E.2d 462 (1963), consequently precluded submission of the case to the jury.

1981At the conclusion of the plaintiffs evidence, the trial court sustained White’s motion to strike the plaintiffs evidence on the ground that the plaintiff had failed to produce evidence overcoming White’s testimony he was in his proper lane of travel and that Weddle, Administratrix v. Draper, 204 Va. 319 , 130 S.E.2d 462 (1963), consequently precluded submission of the case to the jury.

11981–1981

Statutes the citing opinions construe

VA § Va. Code Ann. § 17.1-413 (4) VA § Va. Code Ann. § 18.2-248 (3)

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

TN 45 (2004–2025) OH 38 (1981–2024) WA 35 (1965–2026) GA 33 (1993–2025) CA 33 (1970–2026) TX 32 (1993–2024) MS 27 (1968–2025) PA 26 (1968–2025) IN 22 (1979–2026) FL 18 (1980–2018) IL 17 (1980–2025) VA 11 (1981–2025) IA 10 (2002–2024) MO 9 (1954–2025) WI 9 (1969–2026) MI 8 (1973–2025) AR 7 (2004–2022) NY 7 (1988–2024) AL 7 (1992–2013) KS 7 (1984–2022) MT 6 (1981–2023) MN 6 (1987–2014) KY 6 (2015–2024) AZ 6 (1981–2024) NV 5 (1983–2019) DC 5 (1994–2016) ME 5 (1983–2022) WY 5 (1972–2026) DE 4 (2018–2022) LA 4 (1967–2011) MA 4 (1968–2023) NJ 4 (1964–2024) OR 4 (1996–2011) HI 3 (1999–2024) WV 3 (2011–2012) CT 3 (1994–2018) NC 3 (1986–2005) ID 3 (2011–2019) NE 3 (1991–2022) MD 3 (1967–2006) OK 2 (1995–1996) AK 2 (2007–2013) UT 2 (1994–2020) SC 2 (2003–2019) CO 2 (1967–2025) ND 2 (1982–1989)

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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