motion to suppress hearing (Virginia) · Go Syfert
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motion to suppress hearing in Virginia

10 Virginia opinions name it 2 courts 2008–2024 6 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 (11)

CaseFollowedCited
Davis v. Commonwealthgreen
va · 2011 · cited in 2 Virginia opinions naming this issue, 2014–2014
2 sentences

2014See, e.g., Paugh v. Henrico Area Mental Health & Developmental Servs., 286 Va. 85 , 87 n.1, 743 S.E.2d 277 , 278 n.1 (2013); Davis v. Commonwealth, 282 Va. 339, 339 , 717 S.E.2d 796, 796-97 (2011); Conyers v. Martial Arts World of Richmond, Inc., 273 Va. 96 , 104 n.4, 639 S.E.2d 174 , 177 n.4 (2007).

2014See, e.g., Paugh v. Henrico Area Mental Health & Developmental Servs., 286 Va. 85 , 87 n.1, 743 S.E.2d 277 , 278 n.1 (2013); Davis v. Commonwealth, 282 Va. 339, 339 , 717 S.E.2d 796, 796-97 (2011); Conyers v. Martial Arts World of Richmond, Inc., 273 Va. 96 , 104 n.4, 639 S.E.2d 174 , 177 n.4 (2007).

22
Commonwealth v. Perkins (ORDER)green
· 2018 · cited in 1 Virginia opinions naming this issue, 2024–2024
1 sentence

2024See Code § 17.1-413(A). 1 The Honorable Gary A. Mills presided over the motion to suppress hearing. and regard as true all the credible evidence favorable to the Commonwealth and all fair inferences to be drawn therefrom.” Commonwealth v. Cady, 300 Va. 325 , 329 (2021) (quoting Commonwealth v. Perkins, 295 Va. 323, 324 (2018)).

11
Com. v. Hilliardgreen
va · 2005 · cited in 1 Virginia opinions naming this issue, 2024–2024
1 sentence

2024See Howard v. Commonwealth, 55 Va. App. 417, 425 (2009) (“Settled principles provide that appellant’s brief reference to the constitutional issue in his written - 10 - motion was insufficient to preserve this aspect of the claim for appeal.”), aff’d, 281 Va. 455 (2011); Commonwealth v. Hilliard, 270 Va. 42, 53 (2005) (holding party failed to preserve issue of Sixth Amendment right to counsel where he mentioned it in his written motion to suppress but did not raise it during argument at the motion to suppress hearing and did not ask the trial court to rule on the claim).

11
Howard v. Com.green
va · 2011 · cited in 1 Virginia opinions naming this issue, 2024–2024
1 sentence

2024See Howard v. Commonwealth, 55 Va. App. 417, 425 (2009) (“Settled principles provide that appellant’s brief reference to the constitutional issue in his written - 10 - motion was insufficient to preserve this aspect of the claim for appeal.”), aff’d, 281 Va. 455 (2011); Commonwealth v. Hilliard, 270 Va. 42, 53 (2005) (holding party failed to preserve issue of Sixth Amendment right to counsel where he mentioned it in his written motion to suppress but did not raise it during argument at the motion to suppress hearing and did not ask the trial court to rule on the claim).

11
Howard v. Commonwealthgreen
vactapp · 2009 · cited in 1 Virginia opinions naming this issue, 2024–2024
1 sentence

2024See Howard v. Commonwealth, 55 Va. App. 417, 425 (2009) (“Settled principles provide that appellant’s brief reference to the constitutional issue in his written - 10 - motion was insufficient to preserve this aspect of the claim for appeal.”), aff’d, 281 Va. 455 (2011); Commonwealth v. Hilliard, 270 Va. 42, 53 (2005) (holding party failed to preserve issue of Sixth Amendment right to counsel where he mentioned it in his written motion to suppress but did not raise it during argument at the motion to suppress hearing and did not ask the trial court to rule on the claim).

11
Cooper v. Commonwealthgreen
vactapp · 2009 · cited in 1 Virginia opinions naming this issue, 2024–2024
1 sentence

2024Commonwealth, and regard as true all the credible evidence favorable to the Commonwealth and all fair inferences to be drawn [from that evidence].” Bagley v. Commonwealth, 73 Va. App. 1 , 26 (2021) (alteration in original) (quoting Cooper v. Commonwealth, 54 Va. App. 558, 562 (2009)).

11
Najee Finique Hairston v. Commonwealth of Virginiagreen
vactapp · 2017 · cited in 1 Virginia opinions naming this issue, 2023–2023
1 sentence

2023Hairston v. Commonwealth, 67 Va. App. 552, 560 (2017) (quoting Malborough v. Commonwealth, 275 Va. 163, 168 (2008)). 2 The City of Waynesboro is an independent jurisdiction roughly in the middle of Augusta County. 3 The homeowner’s missing firearm was later recovered in the bedroom, where one of the residents had moved it while waiting for officers to arrive. 4 A year later, at the motion to suppress hearing, Deputy Stroop testified that he could not then recall from memory what the BOLO description said. -2- Deputy Stroop testified that he remembered saying to himself, “Hey; that matches the

11
Malbrough v. Com.green
va · 2008 · cited in 1 Virginia opinions naming this issue, 2023–2023
1 sentence

2023Hairston v. Commonwealth, 67 Va. App. 552, 560 (2017) (quoting Malborough v. Commonwealth, 275 Va. 163, 168 (2008)). 2 The City of Waynesboro is an independent jurisdiction roughly in the middle of Augusta County. 3 The homeowner’s missing firearm was later recovered in the bedroom, where one of the residents had moved it while waiting for officers to arrive. 4 A year later, at the motion to suppress hearing, Deputy Stroop testified that he could not then recall from memory what the BOLO description said. -2- Deputy Stroop testified that he remembered saying to himself, “Hey; that matches the

11
Jay v. Com.green
va · 2008 · cited in 1 Virginia opinions naming this issue, 2023–2023
1 sentence

2023See Rule 5A:20(e); Jay v. Commonwealth, 275 Va. 510, 520 (2008).

11
Ornelas v. United Statesgreen
scotus · 1996 · cited in 1 Virginia opinions naming this issue, 2010–2010
1 sentence

2010Poston. -3- questions of reasonable suspicion and probable cause, we “review findings of historical fact only for clear error 3 and . . . give due weight to inferences drawn from those facts by resident judges and local law enforcement officers.” Ornelas v. United States, 517 U.S. 690, 699 (1996) (footnote added).

11
Wilks v. Commonwealthgreen
va · 1977 · cited in 1 Virginia opinions naming this issue, 2008–2008
2 sentences

2008DeBusk, on the other hand, argues that we do not have jurisdiction to determine whether the dismissal was in error based on the narrow grounds for appeal granted to the Commonwealth by Code § 19.2-398. 3 2 This conclusion is also consistent with analogous decisions involving Chapter 6 of Title 19.2 of the Code of Virginia, relating to “Interception of Wire or Oral Communications.” See, e.g., Wilkes v. Commonwealth, 217 Va. 885, 889-90 , 234 S.E.2d 250, 252-53 (1977) (concluding that the term “oral communication” as defined in Code § 19.2-61(2) does not include a wrongdoer’s recorded statements

2008DeBusk, on the other hand, argues that we do not have jurisdiction to determine whether the dismissal was in error based on the narrow grounds for appeal granted to the Commonwealth by Code § 19.2-398. 3 2 This conclusion is also consistent with analogous decisions involving Chapter 6 of Title 19.2 of the Code of Virginia, relating to “Interception of Wire or Oral Communications.” See, e.g., Wilkes v. Commonwealth, 217 Va. 885, 889-90 , 234 S.E.2d 250, 252-53 (1977) (concluding that the term “oral communication” as defined in Code § 19.2-61(2) does not include a wrongdoer’s recorded statements

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
Ward v. Com. green
va · 2007
2 sentences

2014See, e.g., Branham v. Commonwealth, 283 Va. 273 , 720 S.E.2d 74 (2012) (appellant’s granted assignment of error 7 asserted that “[t]he Court of Appeals erred when it held that the trial court properly admitted the evidence obtained as a result of the search of Mr. Branham’s person and vehicle.”); Pettaway v. Commonwealth, 2010 Va. LEXIS 157 , at *1 (Apr. 8, 2010) (granting an assignment of error stating that “[t]he Court of Appeals erred in affirming the trial court’s decision not to suppress the evidence at the conclusion of the Motion to Suppress hearing on December 12, 2007.”); Ward v. Comm

2014See, e.g., Branham v. Commonwealth, 283 Va. 273 , 720 S.E.2d 74 (2012) (appellant’s granted assignment of error 7 asserted that “[t]he Court of Appeals erred when it held that the trial court properly admitted the evidence obtained as a result of the search of Mr. Branham’s person and vehicle.”); Pettaway v. Commonwealth, 2010 Va. LEXIS 157 , at *1 (Apr. 8, 2010) (granting an assignment of error stating that “[t]he Court of Appeals erred in affirming the trial court’s decision not to suppress the evidence at the conclusion of the Motion to Suppress hearing on December 12, 2007.”); Ward v. Comm

22014–2014
Conyers v. MARTIAL ARTS WORLD OF RICHMOND green
va · 2007
2 sentences

2014See, e.g., Paugh v. Henrico Area Mental Health & Developmental Servs., 286 Va. 85 , 87 n.1, 743 S.E.2d 277 , 278 n.1 (2013); Davis v. Commonwealth, 282 Va. 339, 339 , 717 S.E.2d 796, 796-97 (2011); Conyers v. Martial Arts World of Richmond, Inc., 273 Va. 96 , 104 n.4, 639 S.E.2d 174 , 177 n.4 (2007).

2014See, e.g., Paugh v. Henrico Area Mental Health & Developmental Servs., 286 Va. 85 , 87 n.1, 743 S.E.2d 277 , 278 n.1 (2013); Davis v. Commonwealth, 282 Va. 339, 339 , 717 S.E.2d 796, 796-97 (2011); Conyers v. Martial Arts World of Richmond, Inc., 273 Va. 96 , 104 n.4, 639 S.E.2d 174 , 177 n.4 (2007).

22014–2014
Dixon v. Com. green
va · 2005
2 sentences

2014See, e.g., Branham v. Commonwealth, 283 Va. 273 , 720 S.E.2d 74 (2012) (appellant’s granted assignment of error 7 asserted that “[t]he Court of Appeals erred when it held that the trial court properly admitted the evidence obtained as a result of the search of Mr. Branham’s person and vehicle.”); Pettaway v. Commonwealth, 2010 Va. LEXIS 157 , at *1 (Apr. 8, 2010) (granting an assignment of error stating that “[t]he Court of Appeals erred in affirming the trial court’s decision not to suppress the evidence at the conclusion of the Motion to Suppress hearing on December 12, 2007.”); Ward v. Comm

2014See, e.g., Branham v. Commonwealth, 283 Va. 273 , 720 S.E.2d 74 (2012) (appellant’s granted assignment of error 7 asserted that “[t]he Court of Appeals erred when it held that the trial court properly admitted the evidence obtained as a result of the search of Mr. Branham’s person and vehicle.”); Pettaway v. Commonwealth, 2010 Va. LEXIS 157 , at *1 (Apr. 8, 2010) (granting an assignment of error stating that “[t]he Court of Appeals erred in affirming the trial court’s decision not to suppress the evidence at the conclusion of the Motion to Suppress hearing on December 12, 2007.”); Ward v. Comm

22014–2014
Franks v. Delaware green
scotus · 1978
1 sentence

2024Carson presided over the motion to suppress hearing. 2 Franks v. Delaware, 438 U.S. 154 (1978). motion to suppress based on Rule 3A:9 as an alternative holding.

12024–2024

Statutes the citing opinions construe

VA § Va. Code Ann. § 17.1-413 (8) VA § Va. Code Ann. § 18.2-250 (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

TX 423 (1972–2026) GA 154 (1973–2026) LA 113 (1973–2024) OH 96 (1971–2026) IL 58 (1971–2026) MA 43 (1979–2026) TN 40 (1978–2025) IN 33 (1975–2025) FL 25 (1960–2017) OR 19 (1975–2025) MO 19 (1976–2019) CA 18 (1990–2026) HI 12 (1978–2024) NJ 11 (1976–2019) VA 10 (2008–2024) NC 8 (2019–2025) ID 7 (1986–2025) OK 6 (1971–2012) IA 6 (2014–2026) UT 6 (1990–2026) NM 6 (1980–2023) NE 6 (1994–2023) WY 5 (1995–2025) AZ 4 (1977–2016) ND 4 (2001–2020) RI 4 (1987–2024) ME 3 (2009–2022) DE 3 (2020–2026) WI 3 (1984–2015) KS 3 (1995–2017) PA 3 (2021–2026) CT 3 (2019–2025) AL 2 (1977–1987) AR 2 (2005–2015) WA 2 (2010–2010) MS 2 (2000–2002)

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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