Divisible by 4

February 29, 2012

It’s Leap Day, that special holiday that only comes once every four years and isn’t really a holiday.  I wanted to see if anything of legal interest took place on leap days past.  Westlaw doesn’t allow a date restrictor with a month and day, but no year; it’s not too difficult to work around this, though:

pr(filed released decided published +s feb. february +s 29) (729 Docs)ALLCASES

Of course, if you want to find leap day cases from a particular year, you can just use the normal date restrictor.  For example:

Court & da(02/29/1900) (0 Docs) ALLCASES

That doesn’t seem right.  1900 was a year divisible by 4, there must have been some cases published on leap day that year.  Oh wait, that’s right, leap day occurs in years divisible by 4, but not in years divisible by 100.  A few cases have mentioned and discussed this.

leap +2 day year /p 1900 (3 Docs)ALLCASES

In more practical considerations, an extra day can affect computation of time for anything measured in months or years.  A few prisoners have argued that their prison terms were excessive, as they included extra days from multiple leap years, and a some individuals have tried to argue that Statutes of Limitations ran a day earlier than expected.

378k4 & leap +2 year day (42 Docs)ALLCASES

378k4 is the Key number for Time>Years.  Most jurisdictions seem to have adopted a rule that a ‘year’ is a calendar year, consisting of 366 days in leap years.  For an alternative view, see Sain v. City of Bend, 309 F.3d 1134 (9th Cir. 2002).

See also Jeremy Byellin’s post at WestlawInsider.