12 Va. App. 1040 - Spence v. Commonwealth’s Empirical Analysis
1991
Citation profile
3 federal appellate · 41 state decisions
How this case has been cited
Cited by 44 later decisions — most recently May 2017 · most notably Satcher v. Commonwealth (1992), United States v. Breckenridge (1996)
3 federal appellate · 41 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 Kirkpatrick v. Commonwealth · Lewis v. Commonwealth · Boyd v. Commonwealth · 6 Va. App. 118 - Godwin v. Commonwealth · 7 Va. App. 225 - Cook 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 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A common scheme or plan is present only if the 'relationship among the offenses ... is dependent upon the existence of a plan that ties the offenses together and demonstrates that the objective of each offense was to contribute to the achievement of a goal not obtainable by the commission of any of the individual offenses.'”
3 later decisions quote this exact passage“Two or more offenses, any of which may be a felony or misdemeanor, may be charged in separate counts of an indictment or information if the offenses are based on the same act or transaction, or on two or more acts or transactions that are connected or constitute parts of a common scheme or plan.”
1 later decision quote this exact passage“The court may direct that an accused be tried at one time for all offenses then pending against him, if justice does not require separate trials and (i) the offenses meet the requirements of Rule 3A:6(b) or (ii) the accused and the Commonwealth’s attorney consent thereto.”
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.