nexus requirement (Virginia) · Go Syfert
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nexus requirement in Virginia

7 Virginia opinions name it 3 courts 1994–2013 0 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 (7)

CaseFollowedCited
State v. Peetegreen
wis · 1994 · cited in 1 Virginia opinions naming this issue, 2009–2009
2 sentences

2009See Peete, 517 N.W.2d at 154 (holding that imposing a nexus requirement “makes the language “while possessing’ in [Wisconsin’s statute] parallel in meaning to “while ... using’ or “while ... threatening to use’ ”).

2009Absent a nexus requirement, such a statute “could ... lead to absurd consequences”—“a person could be found guilty of violating [such a] statute when he is found with drugs at his home and a gun at his fishing camp 100 miles away.” Blanchard, 776 So.2d at 1171 ; see Peete, 517 N.W.2d at 153 (“[I]t would be absurd to apply the penalty enhancement statute to situations in which there is no relationship between the offense and possession of a dangerous weapon, regardless of whether that possession is actual or constructive[,]” such as when a person “fills out and files a fraudulent tax return whi

11
United States v. Dennis Allen Hendricksgreen
ca9 · 1984 · cited in 1 Virginia opinions naming this issue, 2007–2007
1 sentence

2007Dennis, 115 F.3d at 530 ; see also Hendricks, 743 F.2d at 655 ; United States v. Dornhofer, 859 F.2d 1195 , 1198 (4th Cir. 1988).

11
Coolidge v. New Hampshiregreen
scotus · 1971 · cited in 1 Virginia opinions naming this issue, 2005–2005
2 sentences

2005See Coolidge v. New Hampshire, 403 U.S. 443, 467 , 91 S.Ct. 2022, 2038-39 , 29 L.Ed.2d 564 (1971) (holding that the Fourth Amendment "requir[es] a 'particular description’ of the thing to be seized").

2005See Coolidge v. New Hampshire, 403 U.S. 443, 467 , 91 S.Ct. 2022, 2038-39 , 29 L.Ed.2d 564 (1971) (holding that the Fourth Amendment "requir[es] a 'particular description’ of the thing to be seized").

11
Sisson v. Rubygreen
scotus · 1990 · cited in 1 Virginia opinions naming this issue, 1997–1997
2 sentences

1997In order to decide whether an activity has a significant relationship to a traditional maritime activity, the court should “determine the potential impact of a given type of incident by examining its general character.” Sisson v. Ruby, 497 U.S. 358, 363 (1990).

1997We are of opinion that, “given ¿he broad perspective demanded” by the nexus test, Sisson, 497 U.S. at 367 , maintaining a vessel’s equipment and its deck under these circumstances is substantially related to traditional maritime activity.

11
Garland Wayne Kelly and Allen Eugene Kelly, Sr. v. J. C. Smith and Chicot Land Company, Inc.green
ca5 · 1973 · cited in 1 Virginia opinions naming this issue, 1997–1997
1 sentence

1997Parenthetically, we note that the Attorney General relies on a four-factor nexus test articulated in Kelly v. Smith, 485 F.2d 520, 525 (5th Cir. 1973).

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

1996See generally Tart, 17 Va.App. 384 , 437 S.E.2d 219 (1993)(addressing the nexus requirement); United States v. Hove, 848 F.2d 137 (9th Cir.1988)(stating that the facts set forth in an affidavit must establish a nexus between the *653 place to be searched and the alleged criminal activity).

1996See generally Tart, 17 Va.App. 384 , 437 S.E.2d 219 (1993)(addressing the nexus requirement); United States v. Hove, 848 F.2d 137 (9th Cir.1988)(stating that the facts set forth in an affidavit must establish a nexus between the *653 place to be searched and the alleged criminal activity).

11
Short Bros. v. Arlington Countygreen
va · 1992 · cited in 1 Virginia opinions naming this issue, 1994–1994
2 sentences

1994The substantial nexus requirement is extracted from a four-prong test established by the Supreme Court in Complete Auto, 430 U.S. at 279 , and adopted by this Court in Short Bros., Inc. v. Arlington County, 244 Va. 520, 524 , 423 S.E.2d 172, 175 (1992).

1994The substantial nexus requirement is extracted from a four-prong test established by the Supreme Court in Complete Auto, 430 U.S. at 279 , and adopted by this Court in Short Bros., Inc. v. Arlington County, 244 Va. 520, 524 , 423 S.E.2d 172, 175 (1992).

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 (7)

CaseCitedYears
Norfolk & Western Railway Co. v. Williams green
va · 1990
1 sentence

2013Id.

12013–2013
State v. Blanchard green
la · 2001
1 sentence

2009Absent a nexus requirement, such a statute “could ... lead to absurd consequences”—“a person could be found guilty of violating [such a] statute when he is found with drugs at his home and a gun at his fishing camp 100 miles away.” Blanchard, 776 So.2d at 1171 ; see Peete, 517 N.W.2d at 153 (“[I]t would be absurd to apply the penalty enhancement statute to situations in which there is no relationship between the offense and possession of a dangerous weapon, regardless of whether that possession is actual or constructive[,]” such as when a person “fills out and files a fraudulent tax return whi

12009–2009
Commonwealth v. Montaque green
ky · 2000
1 sentence

2009“Requiring proof of a nexus between the commission of the offense and the possession of the firearm reduces or eliminates this risk without lessening the statute’s legitimate penal purpose.” Montague, 23 S.W.3d at 632 .

12009–2009
United States v. James John Dornhofer green
ca4 · 1988
1 sentence

2007Dennis, 115 F.3d at 530 ; see also Hendricks, 743 F.2d at 655 ; United States v. Dornhofer, 859 F.2d 1195 , 1198 (4th Cir. 1988).

12007–2007
United States v. Otha Dennis and James Brown, A/K/A Donald Ray Washington green
ca7 · 1997
1 sentence

2007Dennis, 115 F.3d at 530 ; see also Hendricks, 743 F.2d at 655 ; United States v. Dornhofer, 859 F.2d 1195 , 1198 (4th Cir. 1988).

12007–2007
United States v. Kimberly Ann Hove green
ca9 · 1988
2 sentences

1996See generally Tart, 17 Va.App. 384 , 437 S.E.2d 219 (1993)(addressing the nexus requirement); United States v. Hove, 848 F.2d 137 (9th Cir.1988)(stating that the facts set forth in an affidavit must establish a nexus between the *653 place to be searched and the alleged criminal activity).

1996See generally Tart, 17 Va.App. 384 , 437 S.E.2d 219 (1993)(addressing the nexus requirement); United States v. Hove, 848 F.2d 137 (9th Cir.1988)(stating that the facts set forth in an affidavit must establish a nexus between the place to be searched and the alleged criminal activity).

11996–1996
Complete Auto Transit, Inc. v. Brady green
scotus · 1977
1 sentence

1994The substantial nexus requirement is extracted from a four-prong test established by the Supreme Court in Complete Auto, 430 U.S. at 279 , and adopted by this Court in Short Bros., Inc. v. Arlington County, 244 Va. 520, 524 , 423 S.E.2d 172, 175 (1992).

11994–1994

Statutes the citing opinions construe

VA § Va. Code Ann. § 18.2-248.1 (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

WA 74 (1986–2025) TX 66 (1978–2026) IL 32 (1981–2024) CA 27 (1974–2025) FL 26 (1988–2024) NY 21 (1984–2026) NJ 20 (1970–2024) MT 18 (2008–2020) OR 14 (2002–2025) IA 14 (1986–2023) IN 13 (1994–2020) CO 13 (1997–2024) MD 12 (1998–2021) MN 10 (1986–2024) WI 10 (1963–2003) NM 9 (1986–2024) MA 9 (2009–2025) KS 8 (1996–2016) MI 8 (1980–2025) LA 8 (1989–2026) VA 7 (1994–2013) PA 6 (2000–2023) TN 6 (1999–2026) AZ 6 (2004–2024) GA 6 (2016–2025) WY 5 (1984–2006) DE 5 (1987–2026) OH 5 (1995–2025) OK 5 (2011–2026) UT 4 (1989–2006) WV 4 (2007–2026) KY 4 (2000–2024) AL 3 (1992–2013) VT 3 (1980–2004) NH 2 (1977–2003) MO 2 (1983–1987) RI 2 (1993–2007) DC 2 (1996–2000) HI 2 (1998–2012) MS 2 (1992–1995) SC 2 (2011–2013) NE 2 (1980–2024) ID 2 (1988–1996) NC 2 (2022–2022) CT 2 (1988–2008)

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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