facial constitutional challenge (Virginia) · Go Syfert
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facial constitutional challenge in Virginia

8 Virginia opinions name it 3 courts 2002–2025 5 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
Walton v. Commonwealthgreen
vactapp · 1997 · cited in 3 Virginia opinions naming this issue, 2022–2022
2 sentences

2022See Walton v. Commonwealth, 24 Va. App. 757, 761 (1997); Alston v. Commonwealth, 49 Va. App. 115, 122 (2006); Henderson, 59 Va. App. at 665 n.5.

2022See Walton v. Commonwealth, 24 Va. App. 757, 761 (1997); Alston v. Commonwealth, 49 Va. App. 115, 122 (2006); Henderson, 59 Va. App. at 665 n.5.

33
Alston v. Commonwealthgreen
vactapp · 2006 · cited in 3 Virginia opinions naming this issue, 2022–2022
2 sentences

2022See Walton v. Commonwealth, 24 Va. App. 757, 761 (1997); Alston v. Commonwealth, 49 Va. App. 115, 122 (2006); Henderson, 59 Va. App. at 665 n.5.

2022See Walton v. Commonwealth, 24 Va. App. 757, 761 (1997); Alston v. Commonwealth, 49 Va. App. 115, 122 (2006); Henderson, 59 Va. App. at 665 n.5.

33
Hess v. Snyder Hunt Corp.green
va · 1990 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025“All actions of the General Assembly are presumed to be constitutional.” Hess v. Snyder Hunt Corp., 240 Va. 49, 52 (1990).

11
Shin v. Commonwealthgreen
va · 2017 · cited in 1 Virginia opinions naming this issue, 2024–2024
2 sentences

2024Instead, the “litigant must first show ‘that - 17 - the statute in question is unconstitutional as applied to him. [I]f a statute is constitutional as applied to a litigant, he . . . lacks standing to assert a facial constitutional challenge to it, and the statute is not facially unconstitutional because it has at least one constitutional application.’” Shin, 294 Va. at 526 (alteration in original) (quoting Toghill, 289 Va. at 228).

2024“We review questions of statutory constitutionality de novo,” Toghill v. Commonwealth, 289 Va. 220 , 227 (2015), including “a facial constitutional challenge” based on the void-for-vagueness doctrine, Shin v. Commonwealth, 294 Va. 517, 526 (2017).

11
Roberts v. Virginia State Bargreen
va · 2018 · cited in 1 Virginia opinions naming this issue, 2024–2024
2 sentences

2024“When a party makes a vagueness challenge, he generally cannot argue vagaries in aspects of the challenged law that do not directly affect him—a legal claim often called a ‘facial challenge.’” Roberts v. Va. State Bar, 296 Va. 105, 123 (2018) (collecting cases).

2024“The only recognized exception to this general rule involves vagueness challenges to laws that allegedly violate First Amendment rights.” Roberts, 296 Va. at 124 .

11
Washington State Grange v. Washington State Republican Partygreen
scotus · 2008 · cited in 1 Virginia opinions naming this issue, 2017–2017
1 sentence

2017Before a litigant can mount a successful facial challenge to a statute, that litigant must first show "that the statute in question is unconstitutional as applied to him." Id. at 228, 768 S.E.2d at 678 . "[I]f a statute is constitutional as applied to a litigant, he or she lacks standing to assert a facial constitutional challenge to it, and the statute is not facially unconstitutional because it has at least one constitutional application." Id.

11
Palko v. Connecticutred
scotus · 1937 · cited in 1 Virginia opinions naming this issue, 2002–2002
2 sentences

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

11
Benton v. Marylandgreen
scotus · 1969 · cited in 1 Virginia opinions naming this issue, 2002–2002
2 sentences

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

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
Henderson v. Commonwealth green
vactapp · 2012
2 sentences

2022See Walton v. Commonwealth, 24 Va. App. 757, 761 (1997); Alston v. Commonwealth, 49 Va. App. 115, 122 (2006); Henderson, 59 Va. App. at 665 n.5.

2022See Walton v. Commonwealth, 24 Va. App. 757, 761 (1997); Alston v. Commonwealth, 49 Va. App. 115, 122 (2006); Henderson, 59 Va. App. at 665 n.5.

32022–2022
County Court of Ulster Cty. v. Allen green
scotus · 1979
1 sentence

2006Ulster, supra, at 154-55 .

12006–2006
Wilson v. Commonwealth green
va · 1983
2 sentences

2006However, under Wilson v. Commonwealth, 225 Va. 33 , 301 S.E.2d 1 (1983), the court is required to analyze the rebuttable presumptions at issue as permissive inferences, as to which the defendant has no standing to make a facial constitutional challenge.

2006However, under Wilson v. Commonwealth, 225 Va. 33 , 301 S.E.2d 1 (1983), the court is required to analyze the rebuttable presumptions at issue as permissive inferences, as to which the defendant has no standing to make a facial constitutional challenge.

12006–2006
Stromberg v. California green
scotus · 1931
2 sentences

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

12002–2002
Gitlow v. New York green
scotus · 1925
2 sentences

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

12002–2002
Staub v. City of Baxley green
scotus · 1958
2 sentences

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

2002The First Amendment states in part that "Congress shall make no law . . . abridging the freedom of speech." The Supreme Court has stated that this "freedom is among the fundamental personal rights and liberties which are protected by the Fourteenth Amendment from invasion by state action; and municipal ordinances adopted under state authority constitute state action." Staub v. City of Baxley, 355 U.S. 313, 321 , 78 S.Ct. 277 , 2 L.Ed.2d 302 (1958); accord Palko v. Connecticut, 302 U.S. 319, 324-25 , 58 S.Ct. 149 , 82 L.Ed. 288 (1937), overruled on other grounds, Benton v. Maryland, 395 U.S. 78

12002–2002

Statutes the citing opinions construe

VA § Va. Code Ann. § 17.1-413 (4) VA § Va. Code Ann. § 18.2-10 (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

CA 98 (1990–2026) IL 76 (2014–2026) TX 66 (1995–2026) NY 31 (1991–2026) OH 29 (1997–2026) FL 21 (2003–2026) PA 18 (1992–2026) WI 18 (2002–2025) NC 14 (1998–2023) IN 12 (1997–2024) WA 12 (1997–2026) CO 11 (1983–2026) MD 11 (1998–2025) TN 9 (2009–2026) VA 8 (2002–2025) AL 6 (2003–2018) NJ 6 (2001–2021) IA 5 (1979–2025) AZ 5 (2007–2025) UT 5 (1995–2019) MN 5 (1993–2026) NE 4 (2019–2024) MT 4 (2018–2025) MA 4 (1996–2006) LA 4 (2015–2020) MI 3 (2012–2025) KY 3 (2022–2025) ID 3 (1985–2009) AK 3 (2019–2024) KS 2 (2020–2026) DC 2 (1997–2021) HI 2 (2015–2023) ME 2 (2015–2021) NM 2 (1994–1994)

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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