10 Va. App. 686 - Carroll v. Commonwealth’s Empirical Analysis

Citation profile

15 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “authenticated by the clerk of the court where preserved to be a true record, and similarly certified by a judge of that court.”

   2 later decisions quote this exact passage
   e.g. Frank Eddie Dingus v. Commonwealth · 28 Va. App. 1 - Taylor v. Commonwealth

2. “The question before the Court in Hurley was whether a will had been properly certified. The will had been admitted to probate in the county court of Tazewell County, and the certificate of probate, attested by “A.B. Buchanan, Deputy Clerk for S.M. Graham, Clerk of the. Circuit Court of Tazewell County, Virginia” was found to be in proper form and sufficient. The certificate accompanying the actual will, however, contained only the following: “A.B. Buchanan, D. Clerk.” The Supreme Court concluded that the will had been properly certified because the two documents, when read together, met the requirements of Code § 3334. In reaching this conclusion, the court stated: “[UJnder these circumstances, it would be technical in the extreme to reverse the judgment of the circuit court when it plainly can be gathered from the certificate of probate and attestation of the copy of the unit that A.B. Buchanan is the deputy clerk of Tazewell county, authorized by law to act in place of his principal.” Id. at 710, 72 S.E. at 690-91 .”

   1 later decision quote this exact passage · from the majority
   e.g. 22 Va. App. 122 - Ricky Mason Durrette v. County of Spotsylvania

3. “[T]he deficiency in the certificate arises with the signature. The document was not “certified and authenticated” by the clerk but by Peggy B. Elmore. Neither the document itself nor any other evidence in the record establishes that Peggy B. Elmore is authorized by law to act in the place of the clerk. The order does not state that she is a deputy clerk, nor does it contain initials or other indicia to demonstrate that she is a deputy clerk. No evidence was presented to the trial court as to who Peggy B. Elmore is or whether she is authorized to act in place of the clerk.”

   1 later decision quote this exact passage · from the majority
   e.g. 28 Va. App. 1 - Taylor v. Commonwealth