181 W. Va. 106 - State v. Hatfield’s Empirical Analysis
1989
Citation profile
31 state decisions
How this case has been cited
Cited by 31 later decisions — most recently January 2017 · most notably 193 W. Va. 147 - State v. McGinnis (1994), 210 W. Va. 413 - State v. Ladd (2001)
31 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 Raphan v. United States · Zerman v. Melton · Johnson v. Righetti · Royal Netherlands Steamship Co. v. Strachan Shipping Co. · Kelly v. Robinson
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Even where joinder or consolidation of offenses is proper under the West Virginia Rules of Criminal Procedure, the trial court may order separate trials pursuant to Rule 14(a) on the ground that such joinder or consolidation is prejudicial. The decision to grant a motion for severance pursuant to W.Va.R.Crim.P. 14(a) is a matter within the sound discretion of the trial court.”
5 later decisions quote this exact passage“If it appears that a defendant or the state is prejudiced by a joinder of offenses in an indictment or information or by such joinder for trial together, the court may order an election or separate trials of the counts or provide whatever other relief justice requires. In ruling on a motion by a defendant for severance the court may order the attorney for the state to deliver to the court for inspection in camera any statements or confessions made by the defendant or other relevant information which the state intends to introduce in evidence at the trial.”
2 later decisions quote this exact passage · from the dissent“Rule 8(a) is not limited to crimes of the "same" character but also covers those of "similar" character, which means "[n]early corresponding; resembling in many respects; somewhat alike; having a general likeness." Webster's New International Dictionary (2d ed.). As one court pointed out, requiring too precise an identity between the character of the offenses "would fail to give effect to the word `similar' succeeding the word `same' and thus violate an elementary rule of statutory construction." Edwards v. Squier, 178 F.2d 758, 759 (9th Cir.1949) . . . Mere lapse of time between the commission of the offenses does not render joinder improper. United States v. Franklin, 452 F.2d 926 (8th Cir.1971). See also United States v. Pierce, 733 F.2d 1474 (11th Cir.1984); United States v. Rogers [ Rodgers ] 732 F.2d 625 (8th Cir.1984); United States v. Hatcher, 423 F.2d 1086 (5th Cir.), cert. denied, 400 U.S. 848 , 91 S.Ct. 35 , 27 L.Ed.2d 86 (1970); 8 J. Moore, Moore's Federal Practice 8.05[4] (2d ed. 1985). On the other hand, the reason for allowing joinder or consolidation of offenses, namely the promotion of judicial economy by avoidance of needless multiple trials, is not as compelling where the offenses are similar but unrelated.”
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.