19 Va. App. 750 - Bivins v. Commonwealth’s Empirical Analysis
1995
Citation profile
20 state decisions
How this case has been cited
Cited by 25 later decisions — most recently February 2025 · most notably 42 Va. App. 739 - Seaton v. Commonwealth (2004), 26 Va. App. 736 - Jones v. Commonwealth (1998)
20 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 Mason v. Commonwealth · 10 Va. App. 87 - Josephs v. Commonwealth · Johnson v. Commonwealth · Sutton v. Commonwealth · United States v. Slater
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Intimidation is defined as “unlawful coercion; extortion; duress; putting in fear.” “To take or attempt to take, ‘by intimidation’ means willfully to take, or attempt to take, by putting in fear of bodily harm.” Intimidation results when the words or conduct of the accused exercise such domination and control over the victim as to overcome the victim’s mind and overbear the victim’s will, placing the victim in fear of bodily harm.”
4 later decisions quote this exact passage“[W]here the victim's fear results from the taking itself, the taking is not accomplished through intimidation. ... Whether the subjective fear induced by the accused's actions facilitated the taking or merely resulted from the taking will depend on the facts of the individual case. The intent of the accused, if it is merely to take, while not determinative, is a factor in this calculus.”
3 later decisions quote this exact passage“To take or attempt to take, `by intimidation' means willfully to take, or attempt to take, by putting in fear of bodily harm.”
2 later decisions 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.