36 Va. App. 312 - Armstrong v. Commonwealth’s Empirical Analysis
2001
Citation profile
24 state decisions
How this case has been cited
Cited by 24 later decisions — most recently December 2021
24 state decisions
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 Bouie v. City of Columbia · James v. United States · 26 Va. App. 154 - Juares v. Commonwealth · Burns v. Board of Sup'rs of Stafford County · Pulliam v. Coastal Emergency Services of Richmond, Inc.
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Code § 18.2-308.2 provides, in pertinent part: It shall be unlawful for (i) any person who has been convicted of a felony or (ii) any person under the age of twenty-nine who was found guilty as a juvenile fourteen years of age or older at the time of the offense of a delinquent act which would be a felony if committed by an adult, whether such conviction or adjudication occurred under the laws of this Commonwealth, or any other state ..., to knowingly and intentionally possess ... any firearm .... Any person who violates this section shall be guilty of a Class 6 felony. However, any person who violates this section by knowingly and intentionally possessing or transporting any firearm and who was previously convicted of a violent felony as defined in § 17.1-805 shall not be eligible for probation, and shall be sentenced to a minimum, mandatory term of imprisonment of five years____”
1 later decision quote this exact passage““When the legislature has spoken plainly courts may not change or amend legislative enactments under the guise of construing them. The province of construction lies wholly within the domain of ambiguity. ... That which is plain needs no interpretation. Winston v. City of Richmond, 196 Va. 403, 407-08 , 83 S.E.2d 728, 731 (1954).””
1 later decision quote this exact passage“In a prosecution under Code § 18.2-308.2, once the Commonwealth proves the accused is a convicted felon who possessed an object made to “expel a projectile by the combustion of gunpowder or other explosive,” then it has proven all the necessary elements of the crime based on the plain language of the statute.”
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.