Payne v. Commonwealth’s Empirical Analysis
1981
Citation profile
16 state decisions
How this case has been cited
Cited by 16 later decisions — most recently December 2018
16 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 Makarov v. Commonwealth · Patterson v. Bogan · Vaughan v. Lytton · Cook v. Commonwealth · Rosser 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[i]t need not be shown ... that anything was received in return for the check, for the offense is complete when, with the requisite intent, a person utters a check he knows to be worthless.”
2 later decisions quote this exact passage“Any person who, with intent to defraud, shall ... deliver any check ... upon any bank knowing, at the time of such ... delivering, that [he] has not sufficient funds in, or credit with, such bank ... for the payment of such check ... although no express representation is made in reference thereto, shall be guilty of larceny; and, if this check ... has a represented value of $200 or more, such person shall be guilty of a Class 6 felony. The word "credit" as used herein, shall be construed to mean any arrangement or understanding with the bank, trust company, or other depository for the payment of such check, draft or order. Any person ... delivering any such check ... in payment as a present consideration for goods or services for the purposes set out in this section shall be guilty as provided herein.”
1 later decision quote this exact passage · from the dissent“The present statute, Code § 18.2-181, makes Payne’s offense larceny. This poses the question “larceny of what?” In 1978, the legislature clarified the statute’s purpose with this amendment. . . . The Bad Check Act applies a criminal sanction only when a person with the requisite criminal intent utters a worthless check as a present consideration for cash or a cash purchase.”
1 later decision quote this exact passage · from the dissent
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.