20 Va. App. 292 - Ramirez v. Commonwealth’s Empirical Analysis
1995
Citation profile
13 state decisions
How this case has been cited
Cited by 15 later decisions — most recently August 2012
13 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 Davis v. United States · Hardcastle v. Pennsylvania · Spencer v. Commonwealth · Cox v. Commonwealth · Hackman v. Commonwealth
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“employees of DSS involved in the investigation of the child abuse allegation were agents of the Commonwealth for purposes of Rule 3A: 11 (b)(2). Clearly, statements made to these employees and their reports, memoranda, and internal documents were not discoverable. Rule 3A: 11 (b)(2). Moreover, under Rule 3 A: 12, the documents of DSS are not in the possession “of a person not a party to the action.””
1 later decision quote this exact passage“Employees of Commonwealth agencies do not automatically qualify as “agents of the Commonwealth” for purposes of Rule 3A:11. However, where an agency is involved in the investigation or prosecution of a particular criminal case, agency employees become agents of the Commonwealth for purposes of Rule 3A:11 and must be considered a [sic] party to the action for purposes of Rule 3A.T2.”
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.