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← 48 Va. App. 196 - Saunders v. Commonwealth

48 Va. App. 196 - Saunders v. Commonwealth’s Empirical Analysis

2006

Citation profile

18
cited by 18 later decisions
1
states following
November 2013
most recently cited

18 state decisions

Relationships

Relies on 21 Va. App. 519 - Gilliam v. Commonwealth · 19 Va. App. 252 - Alger v. Commonwealth · 20 Va. App. 484 - Mayhew v. Commonwealth · Miller v. Commonwealth · 6 Va. App. 300 - Diggs 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 18 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
  2. “When interpreting statutory language, we must assume that the legislature chose with care the words it used and, where it includes specific language in one section but omits that language from another section, we presume that the exclusion of the language was intentional.”
    1 later decision quote this exact passage
  3. “To the extent appellant's argument may raise due process notice issues, he did not include a due process claim in his petition for appeal, and no appeal was granted on this issue. Thus we may not consider such a claim in this appeal. See Rule 5A: 12(c).”
    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.