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← 13 Va. App. 162 - Commonwealth v. Eaves

13 Va. App. 162 - Commonwealth v. Eaves’s Empirical Analysis

1991

Citation profile

12
cited by 12 later decisions
4
states following
January 2007
most recently cited

2 district · 10 state decisions

Relationships

Relies on Delaware v. Prouse · Higginbotham v. Commonwealth · 9 Va. App. 139 - Murphy v. Commonwealth · Bowie v. Commonwealth · 6 Va. App. 633 - Stroud 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Unlike the situation in [Murphy v. Commonwealth, 9 Va.App. 139 , 384 S.E.2d 125 (1989) ] where no suspicious circumstances existed apart from a lawful turn onto an existing roadway, [the officer who stopped appellee] characterized Eaves’ turn into the deceleration lane as ‘abrupt,’ ‘immediate’ and ‘quick.’ While Eaves was not legally required to give a signal of his intention to turn because no other vehicles were affected by his movement, the fact that he gave his signal while he was making the turn, rather than some distance before, is a factor supporting [the officer’s] conclusion that the decision to turn was not contemplated but, rather, was spontaneous and as a result of Eaves’ observation of the checkpoint. Under the circumstances of this case, as disclosed by the record, we hold that [the officer] possessed reasonable suspicion that Eaves’ purpose in turning was. to avoid the roadblock.”
    1 later decision quote this exact passage
  2. “he stopped the vehicle because of the manner in which the operator made the U-turn, because the turn was abrupt and because the signal was given at the last moment before the turn was executed.”
    1 later decision quote this exact passage
  3. “put on his signal `right at' a turn or deceleration lane leading into a crossover, made a U-turn, and headed back in the northbound lane in the direction from which he had come.”
    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.