10 Va. App. 507 - Carter v. Commonwealth’s Empirical Analysis
1990
Citation profile
29 state decisions
How this case has been cited
Cited by 31 later decisions (2 by the Supreme Court) — most recently March 2019 · most notably Ramdass v. Angelone Director Virginia Department of Corrections (2000), 16 Va. App. 965 - Cox v. Oakwood Mining, Inc. (1993)
29 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 United States v. Bagley · Evans v. Commonwealth · Odum v. Commonwealth · Reiber v. Duncan · Fulcher v. Whitlow
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Before setting aside a verdict, the trial court must have evidence before it to show in a clear and convincing manner `as to leave no room for doubt' that the after-discovered evidence, if true would produce a different result at another trial.”
3 later decisions quote this exact passage“[Sjuch a motion is received cautiously, is awarded with great reluctance, and is addressed to the sound discretion of the trial court.”
3 later decisions quote this exact passage“[A] party who seeks a new trial on the ground of after-discovered evidence must show that he used reasonable diligence to secure such evidence before the earlier trial. It is not sufficient merely to say that the evidence could not have been discovered by the use of due diligence. The applicant for a new trial must set forth in affidavits facts showing what his efforts were to obtain the evidence and explaining why he was prevented from securing it.”
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.