2 Va. App. 84 - Kern v. Commonwealth’s Empirical Analysis
1986
Citation profile
42 state decisions
How this case has been cited
Cited by 42 later decisions — most recently August 2009 · most notably Thomas v. Commonwealth (1993), Thomas v. Com. (1993)
42 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 Stamper v. Commonwealth · Norfolk & Western Railway Co. v. Liepelt · Noll v. Rahal · Simpson v. Commonwealth · Ortiz v. Barrett
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he brochure was prepared as a collection of data customarily available to gemstone appraisers in general. It was analogous to a medical treatise consulted by an expert or to a real estate record consulted by a real estate appraiser. The objective nature of the current market data contained in the brochure lends credence to the trustworthiness of the information.”
2 later decisions quote this exact passage“The standard of review on appeal where the admissibility of expert testimony is challenged is whether the trial court abused its discretion. Thorpe v. Commonwealth, 223 Va. 609, 614 , 292 S.E.2d 323, 326 (1982). It is well established that no formal training or education is necessary to qualify as an expert. Expertise may be acquired through an avocation or a hobby. C. Friend, The Law of Evidence in Virginia, § 215 at 461 (2d Ed. 1983). Knowledge may be the product of home study or experience, or both. Noll v. Rahal, 219 Va. 795, 801 , 250 S.E.2d 741, 745 (1979). All that is necessary for a witness to qualify as an expert is that he have “sufficient knowledge of his subject to give value to his opinion,” Norfolk & Western Railway Co. v. Anderson, 207 Va. 567, 571 , 151 S.E.2d 628, 631 (1966), and that he be better qualified than the jury to form an inference from the facts. C. Friend, The Law of Evidence in Virginia, § 215 at 461 (2d Ed 1983).”
1 later decision quote this exact passage“[w]here a defendant does not object to the accuracy of an order within 21 days after its entry, an appellate court may `presume that the order, as the final pronouncement on the subject, rather than a transcript that may be flawed by omissions, accurately reflects what transpired.'”
1 later decision quote this exact passagee.g. Thomas v. Com.
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.