saving clause (Virginia) · Go Syfert
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saving clause in Virginia

6 Virginia opinions name it 3 courts 1928–2023 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
Ruplenas v. Commonwealthgreen
va · 1981 · cited in 1 Virginia opinions naming this issue, 2023–2023
1 sentence

2023See Ruplenas v. Commonwealth, 221 Va. 972, 977 (1981) (explaining that the general saving statute was “intended to change the common-law rule of abatement”); Holiday v. United States, 683 A.2d 61, 66 (D.C. 1996) (“As a way of preventing abatements of criminal prosecutions and other liabilities when legislatures failed to provide special savings clauses in the repealing legislation, state legislatures . . . adopt[ed] general savings statutes applicable thereafter to all repeals, amendments, and reenactments of criminal and civil liabilities.”); Comment, Today’s Law and Yesterday’s Crime: Retroa

11
Holiday v. United Statesgreen
dc · 1996 · cited in 1 Virginia opinions naming this issue, 2023–2023
1 sentence

2023See Ruplenas v. Commonwealth, 221 Va. 972, 977 (1981) (explaining that the general saving statute was “intended to change the common-law rule of abatement”); Holiday v. United States, 683 A.2d 61, 66 (D.C. 1996) (“As a way of preventing abatements of criminal prosecutions and other liabilities when legislatures failed to provide special savings clauses in the repealing legislation, state legislatures . . . adopt[ed] general savings statutes applicable thereafter to all repeals, amendments, and reenactments of criminal and civil liabilities.”); Comment, Today’s Law and Yesterday’s Crime: Retroa

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 (5)

CaseCitedYears
Scott v. Nance green
va · 1960
2 sentences

1995The material point is whether the second action was brought within [the period of limitation — now two years] if the time during which the first action was pending be excepted therefrom.” See also Scott v. Nance, 202 Va. 355 , 117 S.E.2d 279 (1960).

1995The material point is whether the second action was brought within [the period of limitation — now two years] if the time during which the first action was pending be excepted therefrom.” See also Scott v. Nance, 202 Va. 355 , 117 S.E.2d 279 (1960).

11995–1995
Norwood, Adm'r v. Buffey green
va · 1955
1 sentence

1960In Norwood, Adm'r v. Buffey, supra, 196 Va., at page 1056 , speaking of the saving clause of § 8-634, we said: “The phrase, ‘but if any such action * * * for any cause abates or is dismissed’ is all-embracing.

11960–1960
Carter v. Carter Coal Co. green
scotus · 1936
2 sentences

1938However, under either rule, in the end the test is “What was the intent of the law-makers?” In Carter v. Carter Coal Co., 298 U. S. 238 , 56 S. Ct. 855, 873 , 80 L.

1938However, under either rule, in the end the test is “What was the intent of the law-makers?” In Carter v. Carter Coal Co., 298 U. S. 238 , 56 S. Ct. 855, 873 , 80 L.

11938–1938
Allen v. Mottley Construction Co. green
va · 1933
2 sentences

1937I thought the application of such statutes in the absence of a saving clause in the act was settled by the opinion in Allen v. Mottley Construction Co., 160 Va. 875 , 170 S. E. 412 , and cases therein cited.

1937I thought the application of such statutes in the absence of a saving clause in the act was settled by the opinion in Allen v. Mottley Construction Co., 160 Va. 875 , 170 S. E. 412 , and cases therein cited.

11937–1937
Olin v. Kitzmiller green
scotus · 1922
1 sentence

1928Under the circumstances here presented, without regard to the court where he might ask relief, petitioners’ rights were those recognized by the law of the sea.” In Carlisle Packing Co. v. Sandanger, 259 U. S. 259 , 42 S. Ct. 476 , 66 L.

11928–1928

Where else courts name it

CA 241 (1854–2025) IL 120 (1876–2023) NY 79 (1867–2024) TX 64 (1910–2025) WA 35 (1874–2025) MI 35 (1848–2022) PA 34 (1837–2021) IN 33 (1845–2017) LA 33 (1913–2001) OH 31 (1840–2025) CT 30 (1925–2026) MA 29 (1872–2015) FL 28 (1917–2021) MO 24 (1875–2020) AL 24 (1845–1998) KS 24 (1885–2010) MD 23 (1904–2026) OR 21 (1908–2021) MS 19 (1879–2018) NM 19 (1918–2021) OK 19 (1910–2003) MN 18 (1891–2001) NJ 18 (1942–2024) GA 17 (1908–2024) AZ 14 (1927–2020) NE 13 (1880–2015) TN 13 (1939–2017) IA 13 (1850–2021) NC 13 (1894–2014) AR 12 (1886–2006) KY 12 (1910–2014) CO 12 (1881–2010) WV 11 (1895–2016) ND 10 (1893–2011) SC 8 (1925–2015) MT 8 (1898–2002) RI 7 (1892–1999) PR 7 (1926–1987) NH 7 (1939–2021) HI 6 (1913–2014) SD 6 (1938–2011) ME 6 (1833–1979) VA 6 (1928–2023) VT 5 (1905–2011) DE 5 (1928–1963) WI 5 (1886–2018) WY 4 (1895–1991) DC 3 (1949–1996) UT 3 (1937–2026) VI 2 (2015–2026)

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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