Andrews v. Com.’s Empirical Analysis

Citation profile

20 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[n]othing in this opinion should be construed as barring the Commonwealth from seeking to convict and punish a defendant for capital murder under both Code §§ 18.2-31(7) and - 31(8) where ... the evidence proves that one or more of the constituent killings that form the basis of the latter offense occurred as part of a separate act or transaction from the constituent killings that support the indictment under the former.”

   1 later decision quote this exact passage
   e.g. Charles Stanard Severance v. Commonwealth of Virginia

2. “whether the General Assembly intended through its enactment of Code § 18.2-31(8) to permit the punishment of the commission of two or more murders that occur within a three-year period as a separate offense when all of the constituent crimes for that offense also occur as part of the same act or transaction and the defendant is also convicted and punished for capital murder under Code § 18.2-31(7) in the same trial.”

   1 later decision quote this exact passage
   e.g. Charles Stanard Severance v. Commonwealth of Virginia

3. “[Wjhile Blockburger can provide an efficient mechanism to parse statutory language in order to determine the legislature’s intent with regard to whether multiple punishments are permitted for conduct chargeable under more than one code section, it is not the sole, or in many cases, the primary tool of statutory construction used to determine that intent.”

   1 later decision quote this exact passage
   e.g. 64 Va. App. 156 - Jonathan Marquis Holley v. Commonwealth of Virginia