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← 190 PASUPER 509 - Commonwealth v. Coyle

Commonwealth v. Coyle’s Empirical Analysis

1959

Citation profile

29
cited by 29 later decisions
3
states following
October 1991
most recently cited

29 state decisions

How this case has been cited

Cited by 29 later decisions — most recently October 1991 · most notably Commonwealth v. Meadows (1977), State v. Camp (1974)

29 state decisions

11019591960197019801990decided

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 N.J. Super. 152 - Cortese v. Cortese · Commonwealth v. Jones · Commonwealth v. Wright · Jordan v. Mace · Commonwealth v. Balles

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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[T]he first of many thousands of reported cases in America on this subject (according to 163 A.L.R. 940 ) is Commonwealth v. Zammarelli, 1931, 17 Pa. Dist. & Co. R. 229, in which the late Judge Morrow, of Fayette County, granted the defendant a new trial in a bastardy case because the uncontradicted evidence of a medical expert called by the defendant was that blood tests showed the defendant could not have been the father of the child.”
    2 later decisions quote this exact passage
  2. “The ability of blood grouping tests to exonerate innocent putative fathers was confirmed by a 1976 report developed jointly by the American Bar Association and the American Medical Association. The joint report recommended the use of seven blood test ‘systems’ ABO, Rh, MNSs, Kell, Duffy, Kidd and HLA — when investigating questions of paternity. These systems were found to be ‘reasonable’ in cost and to provide a 91% cumulative probability of negating paternity for erroneously accused Negro men and 93% for white men. The effectiveness of the seven systems attests the probative value of blood test evidence in paternity cases. The importance of that scientific evidence is heightened because ‘[tjhere are seldom accurate or reliable eyewitnesses since the sexual activities usually take place in intimate and private surroundings, and the self-serving testimony of a party is of questionable reliability.’ As Justice BRENNAN wrote while a member of the Appellate Division of the New Jersey Superior Court: “[I]n the field of contested paternity... the truth is so often obscured because social pressures create a conspiracy of silence or, worse, induce deliberate falsity. The value of blood tests as a wholesome aid in the quest for truth in the administration of justice in these matters cannot be gainsaid in this day. Their reliability as an indicator of the truth has been fully established. The substantial weight of medical and legal authority attests their accuracy, not to prove paterni”
    1 later decision quote this exact passage
  3. ““It is universally accepted in medical and scientific fields that the result of a blood grouping test disproving paternity * * * is not an expression of opinion upon which experts can differ but, rather, is the statement of a scientifically established fact. * * * As such it should be accepted by the courts of law. For a court to declare that these tests are not conclusive would be as unrealistic as it would be for a court to declare that the world is flat.””
    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.