Hurd v. Commonwealth’s Empirical Analysis
1932
Citation profile
2 federal appellate · 11 state decisions
How this case has been cited
Cited by 14 later decisions — most recently October 2004
2 federal appellate · 11 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 Pine v. Commonwealth · Allen v. Commonwealth · Burton & Conquest v. Commonwealth · Horton v. Commonwealth · Brown 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘A principal in the second degree is one not the perpetrator, but present, aiding and abetting the act done, or keeping watch or guard at some convenient distance.’ Minor’s Synopsis Crim. Law, page 11. See also Horton's Case, 99 Va. 848 , 38 S. E. 184 . “ ‘Every person who is present at the commission of a trespass, encouraging or inciting the same by words, gestures, looks or signs, or who in any way, or by any means, countenances or approves the same, is, in law, assumed to be an aider and abettor, and is liable as principal.’ Plaintiff’s Instr. No. 1 in Daingerfield v. Thompson, 33 Gratt. (74 Va.) 136, 148, 36 Am. Rep. 783 , approved by this court as the law. “Mere presence when a crime is committed is, of course, not sufficient to render one guilty as an aider or abettor. There must be something to show that the person present and so charged, in some way procured, or incited, or encouraged, the act done by the actual perpetrator. Kemp’s Case, 80 Va. 443, 450 . But whether a person does in fact aid or abet another in the commission of a crime is a question which may be determined by circumstances as well as by direct evidence.” Also see Foster v. Commonwealth, 179 Va. 96 , 18 S. E. (2d) 314 ; James v. Commonwealth, 178 Va. 28 , 16 S. E. (2d) 296 ; Hurd v. Commonwealth, 159 Va. 880 , 165 S. E. 536 ; Hodge v. Winchester, 153 Va. 904 , 150 S. E. 392 ; Boggs v. Commonwealth, 153 Va. 828 , 149 S. E. 445 ; Shiflett v. Commonwealth, 151 Va. 556 , 145 S. E. 336 .”
1 later decision quote this exact passage · from the majority
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.