fact-based inquiry (Virginia) · Go Syfert
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fact-based inquiry in Virginia

7 Virginia opinions name it 4 courts 2002–2026 1 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 (5)

CaseFollowedCited
Bchara v. Bcharagreen
vactapp · 2002 · cited in 4 Virginia opinions naming this issue, 2002–2005
2 sentences

2004She argues the separation did not occur until she actually moved out of the house. - 18 - Whether and when the parties “‘lived separate and apart without cohabitation’ is a fact-based inquiry, requiring examination of all the circumstances before the court.” Bchara, 38 Va. App. at 310 , 563 S.E.2d at 402 (referring to Code § 20-91(A)(9)(a)).

2004She argues the separation did not occur until she actually moved out of the house. - 18 - Whether and when the parties “‘lived separate and apart without cohabitation’ is a fact-based inquiry, requiring examination of all the circumstances before the court.” Bchara, 38 Va. App. at 310 , 563 S.E.2d at 402 (referring to Code § 20-91(A)(9)(a)).

24
Bennett v. Commonwealthgreen
va · 1972 · cited in 1 Virginia opinions naming this issue, 2026–2026
1 sentence

2026See Bennett, 212 Va. at 865 .

11
Wade v. Commonwealthgreen
vactapp · 1990 · cited in 1 Virginia opinions naming this issue, 2020–2020
1 sentence

2020See Roach v. Commonwealth, 51 Va. App. 741, 747-48 (2008) (Code § 19.2-294 did not apply because the “misdemeanor and felony obstruction of justice charges arose from two separate acts, committed by appellant at different times, and in different geographical locations.”); Wade v. Commonwealth, 9 Va. App. 359, 363-65 (1990) (Where both the obstruction of justice charge and the attempted murder charge arose from the same act of firing a gun, the subsequent charge violated Code § 19.2-294 and further noting that the statute “speaks to ‘acts’ of the accused, not elements of the offense.”).

11
Roach v. Commonwealthgreen
vactapp · 2008 · cited in 1 Virginia opinions naming this issue, 2020–2020
1 sentence

2020See Roach v. Commonwealth, 51 Va. App. 741, 747-48 (2008) (Code § 19.2-294 did not apply because the “misdemeanor and felony obstruction of justice charges arose from two separate acts, committed by appellant at different times, and in different geographical locations.”); Wade v. Commonwealth, 9 Va. App. 359, 363-65 (1990) (Where both the obstruction of justice charge and the attempted murder charge arose from the same act of firing a gun, the subsequent charge violated Code § 19.2-294 and further noting that the statute “speaks to ‘acts’ of the accused, not elements of the offense.”).

11
Rickman v. Commonwealthgreen
vactapp · 2000 · cited in 1 Virginia opinions naming this issue, 2002–2002
2 sentences

2002Cf. Rickman v. Commonwealth, 33 Va.App. 550, 557-58 , 535 S.E.2d 187, 191 (2000) (discussing the factors a court should consider to determine whether two people are cohabiting for purposes of Code § 18.2-57.2)i Husband argues the parties did not live separate and apart until May 2000, when wife served husband with divorce papers.

2002Cf. Rickman v. Commonwealth, 33 Va.App. 550, 557-58 , 535 S.E.2d 187, 191 (2000) (discussing the factors a court should consider to determine whether two people are cohabiting for purposes of Code § 18.2-57.2)i Husband argues the parties did not live separate and apart until May 2000, when wife served husband with divorce papers.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Statutes the citing opinions construe

VA § Va. Code Ann. § 20-91 (4) VA § Va. Code Ann. § 20-107.3 (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

CT 65 (1994–2026) CA 29 (1991–2026) IL 24 (2002–2026) NY 20 (1994–2026) PA 16 (1997–2026) OR 14 (1997–2025) TX 12 (2010–2022) DC 12 (1991–2021) OH 11 (1999–2018) IA 10 (2018–2022) NM 8 (1994–2024) VA 7 (2002–2026) MA 7 (1997–2023) WA 7 (2007–2019) NC 6 (2012–2020) CO 6 (2010–2026) FL 6 (1996–2015) MN 6 (1990–2025) MI 5 (2017–2022) UT 5 (2015–2023) KS 4 (2007–2023) SC 4 (2008–2017) LA 3 (1995–2006) DE 3 (2020–2025) MD 3 (2008–2010) GA 3 (2016–2025) ME 2 (1995–2020) OK 2 (1990–2018) NE 2 (2019–2019) NJ 2 (1987–2001) AR 2 (2011–2011) MO 2 (2012–2016)

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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