13 Va. App. 420 - Jenkins v. Commonwealth’s Empirical Analysis
1991
Citation profile
10
cited by 10 later decisions
1
states following
November 2009
most recently cited
10 state decisions
Relationships
Relies on 11 Va. App. 671 - Owusu v. Commonwealth · Commonwealth v. ONE 1970, 2 DR. HT LINCOLN AUTO., ETC. · Haina 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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Forfeiture is, however, not a criminal proceeding but a “civil” action against “res ” unlawfully employed by its owner or other person. Although related to criminal activity, forfeiture is neither “penalty” nor “punishment” for an offense and remains entirely separate and distinct from a prosecution of its owner or other individual.”
2 later decisions quote this exact passage“The order of the trial court confiscating and appropriating defendant’s funds as an incidence of his criminal prosecution did not comply with statutory procedure. Most significantly, the court did not act pursuant to an “information,” with attendant rights, including notice right of trial “independent of any criminal proceeding.” Code § 19.2-386.10; see Code §§ 19.2-386.1, 386.3 and 386.9.”
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.