available test (Virginia) · Go Syfert
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available test in Virginia

8 Virginia opinions name it 2 courts 1977–2023 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 (6)

CaseFollowedCited
Breeden v. Commonwealthgreen
vactapp · 1992 · cited in 3 Virginia opinions naming this issue, 1993–2008
2 sentences

2008This Court interpreted the language in the amended statute to give the driver “a statutory *236 right to choose one of the two tests.” Breeden v. Commonwealth, 15 Va.App. 148, 150 , 421 S.E.2d 674, 675 (1992).

2008This Court interpreted the language in the amended statute to give the driver “a statutory *236 right to choose one of the two tests.” Breeden v. Commonwealth, 15 Va.App. 148, 150 , 421 S.E.2d 674, 675 (1992).

33
Justus v. Com.green
va · 2007 · cited in 2 Virginia opinions naming this issue, 2013–2023
2 sentences

2013Justus, 274 Va. at 154 , 645 S.E.2d at 289 (“the motion [to withdraw the guilty plea] should be granted even if the guilty plea was merely entered ‘inadvisedly’when the evidence supporting the motion shows that there is a reasonable defense to be presented to the judge or jury trying the case” (emphasis added)). 6 Otherwise, a defendant could plead guilty with full knowledge of an available defense to gain delay or for some other tactical reason, and then set the plea aside simply by tendering a defense to the charges.

2013Justus, 274 Va. at 154 , 645 S.E.2d at 289 (“the motion [to withdraw the guilty plea] should be granted even if the guilty plea was merely entered ‘inadvisedly’when the evidence supporting the motion shows that there is a reasonable defense to be presented to the judge or jury trying the case” (emphasis added)). 6 Otherwise, a defendant could plead guilty with full knowledge of an available defense to gain delay or for some other tactical reason, and then set the plea aside simply by tendering a defense to the charges.

22
Lashon Marcay Pritchett v. Commonwealth of Virginiagreen
vactapp · 2013 · cited in 1 Virginia opinions naming this issue, 2022–2022
1 sentence

2022Pritchett v. Commonwealth, 61 Va. App. 777, 788 (2013) (“a defendant could plead guilty with full knowledge of an available defense to gain delay or for some other tactical reason, and then set the plea aside simply by tendering a defense to the charges”).

11
Driver v. Commonwealthgreen
vactapp · 1988 · cited in 1 Virginia opinions naming this issue, 1996–1996
2 sentences

1996If either the blood test or the breath test is not available, then the available test shall be taken____ 1 “Code § 18.2-268 contemplates the existence of both a blood and breath test.” Driver v. Commonwealth, 6 Va.App. 583, 585 , 371 S.E.2d 27, 28 (1988).

1996If either the blood test or the breath test is not available, then the available test shall be taken____ 1 “Code § 18.2-268 contemplates the existence of both a blood and breath test.” Driver v. Commonwealth, 6 Va.App. 583, 585 , 371 S.E.2d 27, 28 (1988).

11
Mason v. Commonwealthgreen
vactapp · 1993 · cited in 1 Virginia opinions naming this issue, 1996–1996
2 sentences

1996“If one of the tests is unavailable the government must provide a reasonable explanation for its unavailability.” Mason v. Commonwealth, 15 Va.App. 583, 585 , 425 S.E.2d 544, 545 (1993).

1996“If one of the tests is unavailable the government must provide a reasonable explanation for its unavailability.” Mason v. Commonwealth, 15 Va.App. 583, 585 , 425 S.E.2d 544, 545 (1993).

11
Beck v. Commonwealthgreen
va · 1975 · cited in 1 Virginia opinions naming this issue, 1977–1977
2 sentences

1977In its opinion the trial court relied on this definition of involuntary manslaughter as restated in Beck Commonwealth, 216 Va. 1, 4 , 216 S.E.2d 8, 9 (1975): {"Involuntary manslaughter is the killing of one accidentally, contrary to the intention of the parties, in the prosecution of some unlawful, but not felonious, act; or in the improper performance of a lawful act." The court cited Bell Commonwealth, 170 Va. 597 , 195 S.E. 675 (1938), as controlling authority for the principle that contributory negligence, an available defense in a civil action for personal injuries or death by wrongful ac

1977In its opinion the trial court relied on this definition of involuntary manslaughter as restated in Beck Commonwealth, 216 Va. 1, 4 , 216 S.E.2d 8, 9 (1975): {"Involuntary manslaughter is the killing of one accidentally, contrary to the intention of the parties, in the prosecution of some unlawful, but not felonious, act; or in the improper performance of a lawful act." The court cited Bell Commonwealth, 170 Va. 597 , 195 S.E. 675 (1938), as controlling authority for the principle that contributory negligence, an available defense in a civil action for personal injuries or death by wrongful ac

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 (2)

CaseCitedYears
Bottoms v. Com. green
va · 2011
2 sentences

2013In Bottoms , the Supreme Court held that the defendant had entered his guilty plea to two charges of construction fraud “inadvisedly” and, therefore, the motion to withdraw the plea should have been granted. 281 Va. at 34 , 704 S.E.2d at 412 .

2013In Bottoms , the Supreme Court held that the defendant had entered his guilty plea to two charges of construction fraud “inadvisedly” and, therefore, the motion to withdraw the plea should have been granted. 281 Va. at 34 , 704 S.E.2d at 412 .

12013–2013
Bell v. Commonwealth green
va · 1938
2 sentences

1977In its opinion the trial court relied on this definition of involuntary manslaughter as restated in Beck Commonwealth, 216 Va. 1, 4 , 216 S.E.2d 8, 9 (1975): {"Involuntary manslaughter is the killing of one accidentally, contrary to the intention of the parties, in the prosecution of some unlawful, but not felonious, act; or in the improper performance of a lawful act." The court cited Bell Commonwealth, 170 Va. 597 , 195 S.E. 675 (1938), as controlling authority for the principle that contributory negligence, an available defense in a civil action for personal injuries or death by wrongful ac

1977In its opinion the trial court relied on this definition of involuntary manslaughter as restated in Beck Commonwealth, 216 Va. 1, 4 , 216 S.E.2d 8, 9 (1975): {"Involuntary manslaughter is the killing of one accidentally, contrary to the intention of the parties, in the prosecution of some unlawful, but not felonious, act; or in the improper performance of a lawful act." The court cited Bell Commonwealth, 170 Va. 597 , 195 S.E. 675 (1938), as controlling authority for the principle that contributory negligence, an available defense in a civil action for personal injuries or death by wrongful ac

11977–1977

Statutes the citing opinions construe

VA § Va. Code Ann. § 18.2-268 (4) VA § Va. Code Ann. § 18.2-266 (3) VA § Va. Code Ann. § 19.2-296 (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

IL 63 (1932–2026) WI 44 (1959–2026) IN 42 (1857–2025) NY 42 (1868–2024) FL 40 (1894–2019) CA 39 (1938–2023) TX 36 (1928–2026) MO 35 (1911–2025) DC 30 (1980–2025) OH 28 (1967–2026) PA 27 (1929–2026) MI 21 (1914–2026) WA 16 (2002–2020) AL 13 (1887–1998) MA 13 (1982–2026) ID 12 (2001–2026) GA 10 (1934–2026) RI 9 (1980–2013) NJ 9 (1932–2021) LA 9 (1958–1997) MT 9 (1985–2023) VA 8 (1977–2023) CO 8 (1988–2022) WV 8 (1908–1997) OR 7 (1960–2023) OK 7 (1903–2023) TN 7 (2002–2016) MD 7 (1970–2016) NM 6 (1923–2022) CT 6 (1990–2015) NE 6 (1994–2024) VT 6 (1892–2016) WY 6 (1884–2023) MS 6 (1999–2014) DE 5 (2000–2022) KS 5 (1996–2020) IA 5 (1952–1984) KY 4 (1871–2024) HI 4 (1995–2018) ME 3 (1979–2021) AR 3 (1992–2025) MN 3 (1998–2024) NH 2 (1995–2024) UT 2 (2012–2017) NC 2 (1994–2010) SD 2 (1998–2003) ND 2 (1958–1995) SC 2 (1970–2017)

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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