Padgett v. Commonwealth’s Empirical Analysis
1980
Citation profile
25 state decisions
How this case has been cited
Cited by 25 later decisions — most recently December 2012 · most notably 14 Va. App. 926 - Lash v. County of Henrico (1992), 15 Va. App. 593 - Slater v. Commonwealth (1993)
25 state decisions
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 Blockburger v. United States · Jones v. Commonwealth
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he bar of Code § 19.2-294.1 encompasses offenses which, although separate and distinct, grow out of "the same act or acts." Thus, the real question in the case is the meaning of a penal nature and is remedial in character, it must be construed strictly against the Commonwealth and favorable to the accused. So construing it, we do not believe that the difference in venue involved in this case alters the singular nature of the act or acts out of which the charges against the defendant arose. We interpret the language, "the same act or acts" to mean "the same act or acts" of driving and to contemplate a continuous, uninterrupted course of operation of a motor vehicle.”
5 later decisions quote this exact passage · from the majority“[w]henever any person is charged with a violation of § 18.2-266 or any similar ordinances of any county, city, or town and reckless driving growing out of the same act or acts and is convicted of one of these charges, the court shall dismiss the remaining charge. 1”
4 later decisions 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.