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← 176 VA 281 - Commonwealth v. Dodson

Commonwealth v. Dodson’s Empirical Analysis

1940

Citation profile

78
cited by 78 later decisions
18
states following
October 2010
most recently cited

1 district · 77 state decisions

How this case has been cited

Cited by 78 later decisions — most recently October 2010 · most notably State Ex Rel. Sego v. Kirkpatrick (1974), 43 Cal. 3d 1078 - Harbor v. Deukmejian (1987)

1 district · 77 state decisions — followed in 18 states

29019401950196019701980199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on Union Pacific Railroad Company v. Mason City Fort Dodge Railroad Company · Fergus v. Russel · Commonwealth v. Barnett · Johnson v. Harrison · Bengzon v. Secretary of Justice of Philippine Islands

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 78 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “"an indivisible sum of money dedicated to a stated purpose. It is something different from a provision or condition * * *."”
    7 later decisions quote this exact passage · from the majority
  2. ““ ... By section 5 of said article 63, ‘the governor may disapprove or reduce items or parts of items in any bill appropriating money. So much of such bill as he approves shall upon his signing the same become law. As to each item disapproved or reduced, he shall transmit to the house in which the bill originated his reason for such disapproval or reduction, and the procedure shall then be the same as in the case of a bill disapproved as a whole.’ The fact that this section relates solely to appropriation bills, in conjunction with the word ‘reduce,’ indicates clearly that the expression ‘items or parts of items’ refers to separable fiscal units. They are appropriations of sums of money. Power is conferred upon the Governor to reduce a sum of money appropriated, or to disapprove the appropriation entirely. No power is conferred to change the terms of an appropriation except by reducing the amount thereof. Words or phrases are not ‘items or parts of items.’ This principle applies to the condition attached to the appropriation now in question. That condition is not an item or a part of an item. The veto power conferred upon the Governor was designed to enable him to recommend the striking out or reduction of any item or part of an item. In the present instance His Excellency the Governor did not undertake to veto the appropriation of $100,000 made by item 101, or any part of it, nor to reduce that amount or any part of it apportioned to a specific purpose. He sought, rather, as”
    1 later decision quote this exact passage · from the majority
  3. ““Its constructon must be liberal and because of this statutes are not to be declared unconstitutional unless that conclusion is inevitable. . . . * * * “All of this we reaffirmed in the late case of West Bros. Brick Co. v. Alexandria, 169 Va. 271 , 192 S.E. 881 , where it is said: ‘“If the title be not misleading and if those things are done which are germane to it, that is enough. This constitutional provision was intended to prevent the insertion of rights or reservations which cannot bear the light of public scrutiny and which, if uncovered, would not be tolerated. Where this is done that provision should be enforced to the letter.’””
    1 later decision quote this exact passage · from the majority

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.