spirit exception (Virginia) · Go Syfert
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spirit exception in Virginia

7 Virginia opinions name it 3 courts 1833–2025 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 (2)

CaseFollowedCited
Independent Investor Protective League v. Time, Inc.green
ny · 1980 · cited in 1 Virginia opinions naming this issue, 2025–2025
1 sentence

2025Protective League v. Time, Inc., 406 N.E.2d 486, 488 (N.Y. 1980) (“[A] shareholder of a dissolved corporation has sufficient interest in a derivative action to satisfy the spirit of the rule requiring ownership at the commencement of the action.”), with, e.g., Fisher v. Liniger, No. 16CV30786, 2016 Colo. Dist.

11
Ellison v. Weintrobgreen
va · 1924 · cited in 1 Virginia opinions naming this issue, 2015–2015
1 sentence

2015Ellison v. Weintraub, 139 Va. 29, 34-35 (1924) (quoting Watson v. Lyle’s Adm’r, 4 Leigh (31 Va.) 236, 249 (1833)).

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 (3)

CaseCitedYears
Freeland v. Heron, Lenox & Co. green
scotus · 1812
2 sentences

1833Saund. 127, d. e. note 7; Freeland v. Heron &c., 7 Cranch, 147 .

1833Saund. 127, d. e. note 7; Freeland v. Heron &c., 7 Cranch, 147 .

31833–1833
Knight v. Watts's Adm'rs neutral
wva · 1885
1 sentence

1943The appellant relies upon Knight v. Watts, 26 W.

11943–1943
Winship v. the Bank of the United States green
scotus · 1831
1 sentence

1856In opposition to Forrester v. Pigou, sustained by a great preponderance of authority, as well as by reason and good sense, the appellant’s counsel cited, and, as it seemed to me, mainly, if not exclusively, relied on, Winship v. Bank U. S, 5 Peters, 529, 552 , (a case similar to that cited from 14 Pickering,) in which the judges of the Supreme Court of the United States were divided in opinion as to the admissibility of one who becomes interested after he has witnessed an instrument, and no judgment was given on the point, and Burgess v. Layne et al., 3 Greenl. 165, Maine Reports, in which the

11856–1856

Where else courts name it

VT 66 (1883–2025) NY 36 (1843–2008) IL 23 (1903–2023) TX 20 (1884–2015) IN 20 (1984–2024) AL 17 (1840–2024) CA 15 (1896–2010) PA 14 (1900–2025) NJ 13 (1933–2025) FL 13 (1970–2011) AZ 12 (1965–2025) MO 11 (1884–2020) IA 10 (1862–2018) WA 9 (1901–2020) KS 8 (1900–2026) WY 8 (1906–2005) OH 8 (1837–2020) MT 8 (1982–2026) SD 8 (1892–1998) DC 7 (1884–2014) VA 7 (1833–2025) ID 7 (1978–2009) WV 7 (1966–2004) CO 7 (1895–2021) MA 7 (1845–2018) TN 6 (1896–2002) MI 6 (1890–2001) GA 6 (1901–1990) WI 5 (1936–2006) MS 5 (1873–2025) NM 5 (1929–2014) AR 5 (1898–2003) CT 5 (1969–2003) OR 4 (1904–1970) NH 4 (1826–2015) NC 4 (1887–2012) MN 4 (1893–2018) ND 3 (1910–2006) KY 2 (1978–2017) HI 2 (1953–1955) LA 2 (1964–1991) MD 2 (1967–2017) SC 2 (1908–1925) DE 2 (2020–2022) RI 2 (2012–2014)

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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