2 Va. App. 549 - Wells v. Commonwealth’s Empirical Analysis
1986
Citation profile
18 state decisions
How this case has been cited
Cited by 18 later decisions — most recently November 2016
18 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 Inge v. Commonwealth · Packer v. Hornsby · Dukes v. Commonwealth · Colbert v. Commonwealth · Crump v. United States Mining Co.
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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“. . . [I]f the proof relied upon by the Commonwealth is wholly circumstantial, as it here is, then to establish guilt beyond a reasonable doubt all necessary circumstances proved must be consistent with guilt and inconsistent with innocence. They must - 8 - overcome the presumption of innocence and exclude all reasonable conclusions inconsistent with that of guilt. To accomplish that, the chain of necessary circumstances must be unbroken and the evidence as a whole must satisfy the guarded judgment that both the corpus delicti and the criminal agency of the accused have been proved to the exclusion of any other rational hypothesis and to a moral certainty. . . .”
2 later decisions quote this exact passage“[T]he absence of paraphernalia, evidence that the defendant used marijuana, evidence of the method of packaging the marijuana, and the absence of unusual amounts of money may all be consistent with the hypothesis of possession for personal use under the facts of a particular case.”
1 later decision quote this exact passage“The quantity of a controlled substance is a factor which may indicate the purpose for which it is possessed. Possession of a small quantity creates an inference that the drug is for personal use.”
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.