11 Va. App. 550 - Stokes v. Commonwealth’s Empirical Analysis

Citation profile

18 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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In any hearing or trial of any criminal offense ..., a certificate of analysis of a person performing an analysis or examination ... shall be admissible in evidence as evidence of the facts therein stated and the results of the analysis or examination referred to therein, provided (i) the certificate of analysis is filed with the clerk of the court hearing the case at least seven days prior to the hearing or trial and (ii) a copy of such certificate is mailed or delivered by the clerk or attorney for the Commonwealth to counsel of record for the accused at least seven days prior to the hearing or trial upon request of such counsel.”

   3 later decisions quote this exact passage
   e.g. 27 Va. App. 71 - Waller v. Commonwealth · 13 Va. App. 333 - Myrick v. Commonwealth

2. “[Code § 19.2-187] deals with criminal matters, and it undertakes to make admissible evidence which otherwise might be subject to a valid hearsay objection. Thus, the statute should be construed strictly against the Commonwealth and in favor of the accused. This rule of construction is particularly applicable to the filing requirements of Code § 19.2-187; these requirements are contained in a proviso to the Code section. The proviso serves to limit and restrain what precedes it in the statute.”

   2 later decisions quote this exact passage
   e.g. 13 Va. App. 333 - Myrick v. Commonwealth · 12 Va. App. 372 - Mullins v. Com.