31 Va. App. 321 - Saunders v. Commonwealth’s Empirical Analysis
2000
Citation profile
8 state decisions
Relationships
Relies on 14 Va. App. 836 - Branch v. Commonwealth · 6 Va. App. 485 - Darnell v. Commonwealth · Livingston v. Commonwealth · 12 Va. App. 7 - Perkins v. Commonwealth · Maye 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In Maye v. Commonwealth, the Supreme Court of Virginia stated: A claim that a statute on its face contains no requirement of mens rea or scienter is no ground for holding the statute unconstitutional since such requirement will be read into the statute by the court when it appears the legislature implicitly intended that it must be proved. 213 Va. 48, 49 , 189 S.E.2d 350, 351 (1972). Therefore, Code § 18.2-83 can be read as requiring a criminal mens rea. Such a narrowing construction of this statute prevents overbreadth. Only an individual who maliciously “makes and communicates ... any threat” prohibited by the statute will be punished.”
1 later decision quote this exact passage“is simply the unlawful intent or design necessary to any criminal act that is not a strict liability offense. See Reed v. Commonwealth, 15 Va.App. 467 , 424 S.E.2d 718 (1992); 1 Wayne R. LaFave, Substantive Criminal Law, § 3.4 (1986); Livingston v. Commonwealth, 184 Va. 830 , 36 S.E.2d 561 (1946).”
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.