Couplin v. Payne’s Empirical Analysis

Citation profile

26 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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[i]n Virginia, a government agent entitled to the protection of sovereign immunity is not immunized from suit. Rather, the degree of negligence which must be shown to impose liability is elevated from simple to gross negligence.”

   2 later decisions quote this exact passage
   e.g. Couplin v. Metropolitan Washington Airport Authority · Graham v. City of Manassas Sch. Bd.

2. “When an enactment does not encompass the entire subject covered by the common law, it abrogates the common-law rule only to the extent that its terms are directly and irreconcilably opposed to the rule.”

   1 later decision quote this exact passage
   e.g. Isbell v. Commercial Inv. Associates, Inc.

3. “[a] statutory change in the common law is limited to that which is expressly stated in the statute or necessarily implied by its language because there is a presumption that no change was intended.”

   1 later decision quote this exact passage
   e.g. Isbell v. Commercial Inv. Associates, Inc.