Rose v. Commonwealth’s Empirical Analysis

Citation profile

16 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Code §§ 46.2-351 et seq., by requiring that one "be direct[ed] . . . not to operate a motor vehicle on the highways in the Commonwealth and to surrender to the court all licenses or permits to drive a motor vehicle on the highways in the Commonwealth" before such person can be guilty of driving a vehicle "while the order of the court prohibiting such operation remains in effect," requires proof of actual knowledge that one has been declared to be an habitual offender before one can be convicted of driving after having been so declared and ordered not to drive. . . . [T]he provisions in Code § 46.2-355 that the order direct the person not to drive and to surrender his license, and the further directive that a copy of the order be mailed to the defendant if it appears he was not present, bespeak a requirement that the person receive actual notice of having been declared an habitual offender and directed not to drive before he can be convicted and imprisoned for driving after having been declared an habitual offender.”

   1 later decision quote this exact passage · from the majority
   e.g. 49 Va. App. 251 - Bishop v. Commonwealth

2. “unlawful for any person determined or adjudicated [a] habitual offender to drive any motor vehicle ... on the highways of the Commonwealth while the revocation of the person's driving privilege remains in effect.”

   1 later decision quote this exact passage · from the majority
   e.g. Com. v. Norman