venue challenge (Virginia) · Go Syfert
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venue challenge in Virginia

6 Virginia opinions name it 2 courts 2006–2025 2 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 (4)

CaseFollowedCited
Richmond Engineering & Manufacturing Corp. v. Lothgreen
va · 1923 · cited in 2 Virginia opinions naming this issue, 2025–2025
2 sentences

2025In Richmond Engineering & Manufacturing Corp. v. Loth, 135 Va. 110, 158 (1923), the Supreme Court of Virginia held that territorial jurisdiction is not merely a venue requirement but a necessary condition for a court to exercise subject-matter jurisdiction over a lien enforcement suit.

2025In Richmond Engineering & Manufacturing Corp. v. Loth, 135 Va. 110, 158 (1923), the Supreme Court of Virginia held that territorial jurisdiction is not merely a venue requirement but a necessary condition for a court to exercise subject-matter jurisdiction over a lien enforcement suit.

22
Williams v. Commonwealthgreen
va · 1948 · cited in 2 Virginia opinions naming this issue, 2006–2008
2 sentences

2008“Accurately speaking,” the Virginia Supreme Court has explained, a venue challenge in such a case is nothing more than the defendant claiming “the evidence is insufficient to establish his presence ... where and when the crime was committed.” Williams v. Commonwealth, 188 Va. 583, 594 , 50 S.E.2d 407, 412 (1948).

2008“Accurately speaking,” the Virginia Supreme Court has explained, a venue challenge in such a case is nothing more than the defendant claiming “the evidence is insufficient to establish his presence ... where and when the crime was committed.” Williams v. Commonwealth, 188 Va. 583, 594 , 50 S.E.2d 407, 412 (1948).

22
Laughner v. Stategreen
indctapp · 2002 · cited in 1 Virginia opinions naming this issue, 2011–2011
1 sentence

2011Id,; see also Laughner v. State, 769 N.E.2d 1147, 1153, 1157 (Ind.Ct.App.2002) (for the statutory crime of solicitation of a minor, which provided a heightened penalty if committed using a computer network, holding venue was proper both in the county from which the defendant sent the message and in the county in which the victim received it because the defendant “took ... ‘action directed at’ the second county”).

11
Green v. Commonwealthgreen
vactapp · 2000 · cited in 1 Virginia opinions naming this issue, 2006–2006
2 sentences

2006“Accurately speaking,” the Virginia Supreme Court has explained, a venue challenge in such a case is nothing more than the defendant claiming “the evidence is insufficient to establish his 3 See also Green v. Commonwealth, 32 Va. App. 438, 450 , 528 S.E.2d 187, 193 (2000) (remanding for “retrial in a proper venue” when the “Commonwealth did not meet its burden to establish venue” because “‘venue is not part of the crime’” (quoting Randall, 183 Va. at 187 , 31 S.E.2d at 573 )). -5- presence . . . where and when the crime was committed.” Williams v. Commonwealth, 188 Va. 583, 594 , 50 S.E.2d 407

2006“Accurately speaking,” the Virginia Supreme Court has explained, a venue challenge in such a case is nothing more than the defendant claiming “the evidence is insufficient to establish his 3 See also Green v. Commonwealth, 32 Va. App. 438, 450 , 528 S.E.2d 187, 193 (2000) (remanding for “retrial in a proper venue” when the “Commonwealth did not meet its burden to establish venue” because “‘venue is not part of the crime’” (quoting Randall, 183 Va. at 187 , 31 S.E.2d at 573 )). -5- presence . . . where and when the crime was committed.” Williams v. Commonwealth, 188 Va. 583, 594 , 50 S.E.2d 407

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 (4)

CaseCitedYears
Craig & Bumgardner v. Hoge & Hutchinson neutral
va · 1897
2 sentences

2025Relying on Spiller v. Wells, 96 Va. 598 (1899), and Craig v. Hoge, 95 Va. 275 (1897), the Supreme Court explained that “the institution of such a suit confers upon the court in which it is brought, if that court has territorial jurisdiction, exclusive jurisdiction of the subject matter and of all of the parties before the court in such suit.” Loth, 135 Va. at 158 (emphasis added).

2025Relying on Spiller v. Wells, 96 Va. 598 (1899), and Craig v. Hoge, 95 Va. 275 (1897), the Supreme Court explained that “the institution of such a suit confers upon the court in which it is brought, if that court has territorial jurisdiction, exclusive jurisdiction of the subject matter and of all of the parties before the court in such suit.” Loth, 135 Va. at 158 (emphasis added).

22025–2025
Spiller v. Wells green
va · 1899
2 sentences

2025Relying on Spiller v. Wells, 96 Va. 598 (1899), and Craig v. Hoge, 95 Va. 275 (1897), the Supreme Court explained that “the institution of such a suit confers upon the court in which it is brought, if that court has territorial jurisdiction, exclusive jurisdiction of the subject matter and of all of the parties before the court in such suit.” Loth, 135 Va. at 158 (emphasis added).

2025Relying on Spiller v. Wells, 96 Va. 598 (1899), and Craig v. Hoge, 95 Va. 275 (1897), the Supreme Court explained that “the institution of such a suit confers upon the court in which it is brought, if that court has territorial jurisdiction, exclusive jurisdiction of the subject matter and of all of the parties before the court in such suit.” Loth, 135 Va. at 158 (emphasis added).

22025–2025
State Farm Mutual Automobile Insurance v. Powell green
va · 1984
2 sentences

2015State Farm Mutual Automobile Insurance Co. v. Powell, 227 Va. 492 , 318 S.E.2d 393 (1984) is inapposite because in that 20 case, the trial court took judicial notice of certain facts sua sponte, thereby depriving the defendant of the opportunity to be heard and to object.

2015State Farm Mutual Automobile Insurance Co. v. Powell, 227 Va. 492 , 318 S.E.2d 393 (1984) is inapposite because in that 20 case, the trial court took judicial notice of certain facts sua sponte, thereby depriving the defendant of the opportunity to be heard and to object.

12015–2015
Randall v. Commonwealth green
va · 1944
2 sentences

2006“Accurately speaking,” the Virginia Supreme Court has explained, a venue challenge in such a case is nothing more than the defendant claiming “the evidence is insufficient to establish his 3 See also Green v. Commonwealth, 32 Va. App. 438, 450 , 528 S.E.2d 187, 193 (2000) (remanding for “retrial in a proper venue” when the “Commonwealth did not meet its burden to establish venue” because “‘venue is not part of the crime’” (quoting Randall, 183 Va. at 187 , 31 S.E.2d at 573 )). -5- presence . . . where and when the crime was committed.” Williams v. Commonwealth, 188 Va. 583, 594 , 50 S.E.2d 407

2006“Accurately speaking,” the Virginia Supreme Court has explained, a venue challenge in such a case is nothing more than the defendant claiming “the evidence is insufficient to establish his 3 See also Green v. Commonwealth, 32 Va. App. 438, 450 , 528 S.E.2d 187, 193 (2000) (remanding for “retrial in a proper venue” when the “Commonwealth did not meet its burden to establish venue” because “‘venue is not part of the crime’” (quoting Randall, 183 Va. at 187 , 31 S.E.2d at 573 )). -5- presence . . . where and when the crime was committed.” Williams v. Commonwealth, 188 Va. 583, 594 , 50 S.E.2d 407

12006–2006

Statutes the citing opinions construe

VA § Va. Code Ann. § 19.2-244 (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

TX 291 (1917–2026) FL 77 (1957–2026) LA 37 (1962–2025) PA 35 (1974–2025) CA 25 (1964–2025) MS 24 (1986–2025) NY 23 (1943–2024) IL 21 (1957–2025) OH 18 (1972–2026) AL 17 (1981–2018) MI 14 (1987–2023) OR 14 (1980–2026) WA 14 (1950–2021) MO 13 (1899–2024) GA 12 (1992–2025) WI 9 (1969–2025) AZ 9 (1977–2021) IN 8 (1983–2025) VA 6 (2006–2025) KS 6 (2005–2022) CT 6 (1982–2017) MN 6 (2009–2026) NE 5 (2000–2019) IA 5 (1977–2023) MA 5 (1977–2002) MD 5 (1978–2013) SC 5 (1989–2018) OK 4 (1929–2014) MT 4 (1958–2009) NJ 4 (1979–2008) WV 4 (1988–2021) NM 4 (1981–2019) CO 3 (1982–2011) UT 3 (1997–2023) NH 2 (1994–2007) ND 2 (1978–2010) SD 2 (1993–2020) NC 2 (2013–2024) TN 2 (1985–2015) AR 2 (1931–2016) AK 2 (2002–2018)

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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