Commonwealth v. Bruhn’s Empirical Analysis

Citation profile

30 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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “a presumption exists that a substantive change in law was intended by an amendment to an existing statute,”

   2 later decisions quote this exact passage · from the dissent
   e.g. Graves v. Commonwealth · REVI, LLC v. Chicago Title Insurance Co.

2. “In 1994, however, the General Assembly amended Code § 18.2-111 and deleted the language that permitted a defendant who had committed embezzlement to be “indicted as for larceny.” The amendment further eliminated the phrase that made proof of embezzlement “sufficient to sustain the charge” of larceny and the requirement that the Commonwealth elect, upon motion of the defendant, the specific statutory theory of the crime of larceny it intended to rely upon for a conviction.”

   1 later decision quote this exact passage · from the dissent
   e.g. 46 Va. App. 25 - Hunt v. Commonwealth

3. ““As a general rule, a presumption exists that a substantive change in law was intended by an amendment to an existing statute.” Thus, in construing a statute that has been amended by the General Assembly, we presume that the legislature acted with full knowledge of the law as it affected the subject matter. It is our task ... to adopt a construction that gives import to the legislative purpose and the words used.”

   1 later decision quote this exact passage · from the dissent
   e.g. 42 Va. App. 203 - Bazemore v. Commonwealth