13 Va. App. 333 - Myrick v. Commonwealth’s Empirical Analysis
1991
Citation profile
33 state decisions
How this case has been cited
Cited by 33 later decisions — most recently July 2012 · most notably Robinson v. State (1997), 29 Va. App. 548 - Ellis v. Commonwealth (1999)
33 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 10 Va. App. 87 - Josephs v. Commonwealth · Brooks v. City of Newport News · Carmody v. F. W. Woolworth Co. · Gray v. Commonwealth · 3 Va. App. 657 - Allen 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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In any hearing or trial of any criminal offense ... a certificate of analysis of a person performing an analysis or examination, performed in any laboratory operated by the Division of Consolidated Laboratory Services or the Division of Forensic Science ... 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 made by such counsel to the clerk with notice of the request to the attorney for the Commonwealth.”
1 later decision quote this exact passage“objection on the ground that a copy rather than the original was filed raises neither a hearsay question nor a filing problem under Code § 19.2-187. Rather, [his] objection raises a “best evidence” question, which is whether a copy of the certificate of analysis qualifies as an original or can be filed in lieu of the original for the purposes of pretrial filing as required by Code § 19.2-187.”
1 later decision quote this exact passage“The best evidence rule requires that, to prove the contents of a document, the `original must be produced unless it be shown that the original is unavailable, in which case secondary evidence may be introduced.'”
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.