2 Va. App. 639 - Walls v. Commonwealth’s Empirical Analysis
1986
Citation profile
97 state decisions
How this case has been cited
Cited by 97 later decisions — most recently May 2015 · most notably 6 Va. App. 507 - Servis v. Commonwealth (1988), 28 Va. App. 187 - Timbers v. Commonwealth (1998)
97 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 Wong Sun v. United States · Schneckloth v. Bustamonte · United States v. Leon · Payton v. New York · Brown v. Illinois
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 97 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) a reasonable probability that the evidence in question would have been discovered by lawful means but for the police misconduct, (2) that the leads making the discovery inevitable were possessed by the police at the time of the misconduct, and (3) that the police also prior to the misconduct were actively pursuing the alternative line of investigation.”
7 later decisions quote this exact passage“[t]he [Commonwealth] ... bears the burden of establishing consent and this burden is heavier where the alleged consent is based on an implication.”
3 later decisions quote this exact passage“is well settled that the burden is on the Commonwealth to establish an exception to the warrant requirement.”
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.