20 Va. App. 447 - Barfield v. Commonwealth’s Empirical Analysis
1995
Citation profile
6
cited by 6 later decisions
1
states following
March 2017
most recently cited
6 state decisions
Relationships
Relies on Illinois v. Allen · Diaz v. United States · Taylor v. United States · Crosby v. United States · Eagle-Picher Industries, Inc. v. Liberty Mutual Insurance
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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As a general matter, the costs of suspending a proceeding already under way will be greater than the cost of postponing a trial not yet begun---- [Additionally,] the defendant’s initial presence serves to assure that any waiver is indeed knowing. “Since the notion that trial may be commenced in absentia still seems to shock most lawyers, it would hardly seem appropriate to impute knowledge that this will occur to their clients.” It is unlikely, on the other hand, “ ‘that a defendant who flees from a courtroom in the midst of a trial—where judge, jury, witnesses and lawyers are present and ready to continue—would not know that as a consequence the trial could continue in his absence.’ ” Moreover, a rule that allows an ongoing trial to continue when a defendant disappears deprives the defendant of the option of gambling on an acquittal knowing that he can terminate the trial if it seems that the verdict will go against him—an option that might otherwise appear preferable to the costly, perhaps unnecessary, path of becoming a fugitive from the outset.”
2 later decisions quote this exact passage“[t]he general disruption to the proper administration of the criminal justice system is such that the Commonwealth should not have to prove any special prejudice when the defendant absconds after the trial has commenced, ... prejudice to the Commonwealth’s case due to a continuance must be shown in order for the court to proceed in the defendant’s absence [in] those cases where the trial ha[s] not yet commenced.”
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.