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8 Virginia opinions name it 1 courts 1997–2026 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.
| Case | Followed | Cited |
|---|---|---|
McGee v. Commonwealthgreen2 sentences2003McGee, 25 Va.App. at 200-01 , 487 S.E.2d at 262-63 ; see also *693 Davis, 37 Va.App. at 431-32 , 559 S.E.2d at 379 (a “specific allegation of criminal wrongdoing to the suspect ... is highly significant among the totality of factors,” but it does not “automatically negate a finding of a consensual encounter”). 2003McGee, 25 Va.App. at 200-01 , 487 S.E.2d at 262-63 ; see also *693 Davis, 37 Va.App. at 431-32 , 559 S.E.2d at 379 (a “specific allegation of criminal wrongdoing to the suspect ... is highly significant among the totality of factors,” but it does not “automatically negate a finding of a consensual encounter”). | 1 | 3 |
Davis v. Commonwealthgreen2 sentences2022See Barkley v. Commonwealth, 39 Va. App. 682, 692-93 (2003) (alteration in original) (quoting Davis v. Commonwealth, 37 Va. App. 421, 431-32 (2002)). 2010Davis, 37 Va. App. at 431-32 , 559 S.E.2d at 379 (citing McGee, 25 Va. App. at 196 , 487 S.E.2d at 260 ). | 1 | 2 |
Frazier v. Cuppgreen1 sentence2026Harrison v. Commonwealth, 244 Va. 576, 583-84 (1992); Rodgers v. Commonwealth, 227 Va. 605, 616 (1984); see also Frazier v. Cupp, 394 U.S. 731, 739 (1969) (police misrepresentation that an accomplice had confessed did not render the defendant’s confession involuntary). | 1 | 1 |
Harrison v. Commonwealthgreen2 sentences2026Harrison v. Commonwealth, 244 Va. 576, 583-84 (1992); Rodgers v. Commonwealth, 227 Va. 605, 616 (1984); see also Frazier v. Cupp, 394 U.S. 731, 739 (1969) (police misrepresentation that an accomplice had confessed did not render the defendant’s confession involuntary). 2026Under Virginia law, even promises of leniency are one factor in the totality analysis and are “generally . . . insufficient to overbear a defendant’s free will.” Harrison, 244 Va. at 584 n.2 (quoting Rodgers, 227 Va. at 616 ). | 1 | 1 |
Rodgers v. Commonwealthgreen2 sentences2026Harrison v. Commonwealth, 244 Va. 576, 583-84 (1992); Rodgers v. Commonwealth, 227 Va. 605, 616 (1984); see also Frazier v. Cupp, 394 U.S. 731, 739 (1969) (police misrepresentation that an accomplice had confessed did not render the defendant’s confession involuntary). 2026Under Virginia law, even promises of leniency are one factor in the totality analysis and are “generally . . . insufficient to overbear a defendant’s free will.” Harrison, 244 Va. at 584 n.2 (quoting Rodgers, 227 Va. at 616 ). | 1 | 1 |
Landrum v. CHIPPENHAM AND JOHNSTON-WILLISgreen1 sentence2024Given the totality of factors at work here—and given the circuit court’s correct reading of the W.D.A.—the circuit court did not commit an error of judgment requiring reversal. - 15 - Primov, 296 Va. at 68 (quoting Landrum v. Chippenham & Johnston-Willis Hosps., Inc., 282 Va. 346, 352 (2011)). | 1 | 1 |
Barkley v. Commonwealthgreen1 sentence2022See Barkley v. Commonwealth, 39 Va. App. 682, 692-93 (2003) (alteration in original) (quoting Davis v. Commonwealth, 37 Va. App. 421, 431-32 (2002)). | 1 | 1 |
Simmons v. Commonwealthgreen1 sentence2022See Hairston v. Commonwealth, 67 Va. App. 552, 563 (2017) (“[I]t it irrelevant whether the accused is . . . charged with[] the offense that provided [reasonable suspicion or] probable cause for . . . [the] seizure in the first instance.”); see also United States v. Torres-Ramos, 536 F.3d 542, 552 (6th Cir. 2008) (considering window tint in the totality analysis for reasonable suspicion). - 10 - essence of good police work to adopt an intermediate response.”), quoted in Simmons v. Commonwealth, 217 Va. 552, 554 (1977). | 1 | 1 |
United States v. Torres-Ramosgreen1 sentence2022See Hairston v. Commonwealth, 67 Va. App. 552, 563 (2017) (“[I]t it irrelevant whether the accused is . . . charged with[] the offense that provided [reasonable suspicion or] probable cause for . . . [the] seizure in the first instance.”); see also United States v. Torres-Ramos, 536 F.3d 542, 552 (6th Cir. 2008) (considering window tint in the totality analysis for reasonable suspicion). - 10 - essence of good police work to adopt an intermediate response.”), quoted in Simmons v. Commonwealth, 217 Va. 552, 554 (1977). | 1 | 1 |
Najee Finique Hairston v. Commonwealth of Virginiagreen1 sentence2022See Hairston v. Commonwealth, 67 Va. App. 552, 563 (2017) (“[I]t it irrelevant whether the accused is . . . charged with[] the offense that provided [reasonable suspicion or] probable cause for . . . [the] seizure in the first instance.”); see also United States v. Torres-Ramos, 536 F.3d 542, 552 (6th Cir. 2008) (considering window tint in the totality analysis for reasonable suspicion). - 10 - essence of good police work to adopt an intermediate response.”), quoted in Simmons v. Commonwealth, 217 Va. 552, 554 (1977). | 1 | 1 |
Dickerson v. Commonwealthgreen2 sentences2010Dickerson v. Commonwealth, 266 Va. 14, 18 , 581 S.E.2d 195, 197 (2003) (quoting Drayton, 536 U.S. at 234 ). 3 Appellant also contends that Officer Stewart made a “specific allegation of criminal wrongdoing” against him and that this “factor is highly significant among the totality of factors” in determining whether the encounter with Officer Stewart became a seizure. 2010Dickerson v. Commonwealth, 266 Va. 14, 18 , 581 S.E.2d 195, 197 (2003) (quoting Drayton, 536 U.S. at 234 ). 3 Appellant also contends that Officer Stewart made a “specific allegation of criminal wrongdoing” against him and that this “factor is highly significant among the totality of factors” in determining whether the encounter with Officer Stewart became a seizure. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Colorado v. Connelly
green
1 sentence2026Under Connelly, 479 U.S. at 167 , coercive police activity is a necessary predicate to a finding of involuntariness, so Virginia precedent requires courts to evaluate any promises or inducements within the totality of the circumstances rather than treating them as dispositive in isolation. | 1 | 2026–2026 |
United States v. Drayton
green
1 sentence2010Dickerson v. Commonwealth, 266 Va. 14, 18 , 581 S.E.2d 195, 197 (2003) (quoting Drayton, 536 U.S. at 234 ). 3 Appellant also contends that Officer Stewart made a “specific allegation of criminal wrongdoing” against him and that this “factor is highly significant among the totality of factors” in determining whether the encounter with Officer Stewart became a seizure. | 1 | 2010–2010 |
Linkous v. Kingery
green
2 sentences1997Linkous, 10 Va.App. at 56 , 390 S.E.2d at 194 . 1997Linkous, 10 Va.App. at 56 , 390 S.E.2d at 194 . | 1 | 1997–1997 |
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.
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.