Public-domain · open source
OpenJurist
← 237 Va. 509 - Scarpa v. Melzig

Scarpa v. Melzig’s Empirical Analysis

1989

Citation profile

44
cited by 44 later decisions
1
states following
September 2018
most recently cited

3 federal appellate · 32 state decisions

How this case has been cited

Cited by 44 later decisions — most recently September 2018 · most notably Renner v. Stafford (1993), Starnes v. Cayouette (1992)

3 federal appellate · 32 state decisions

3201989199020002010decided

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 Locke v. Johns-Manville Corp. · Richmond Redevelopment & Housing Authority v. Laburnum Construction Corp.

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

  1. “Moreover, when any injury, though slight, is sustained as the consequence of an alleged wrong, the right of action for a personal injury accrues and the statute of limitations begins to run at once. [Citation omitted.] It is immaterial that all the damages resulting from the wrong may not have been sustained at the time of the negligent act; the running of the statute of limitations is not postponed by the fact that substantial damages do not occur until a later date.”
    3 later decisions quote this exact passage
  2. “The applicable statute provides .... that “every action for personal injuries, whatever the theory of recovery ... shall be brought within two years after the cause of action accrues.” Code § 8.01-243(A). Accrual of the cause of action is governed by Code § 8.01-230 which provides ... that a “cause of action shall be deemed to accrue and the prescribed limitation period shall begin to run from the date the injury is sustained in the case of injury to the person ... and not when the resulting damage is discovered ....” We construed the word “injury” as used in Code § 8.01-230 “to mean positive physical or mental hurt to the claimant.” Locke v. Johns-Manville Corp., 221 Va. 951, 957 , 275 S.E.2d 900, 904 (1981).”
    1 later decision quote this exact passage

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.