20 Va. App. 94 - Pollard v. Commonwealth’s Empirical Analysis
1995
Citation profile
2 federal appellate · 10 state decisions
How this case has been cited
Cited by 12 later decisions — most recently April 2017
2 federal appellate · 10 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 Essex v. Commonwealth · Hubbard v. Commonwealth · Beck v. Commonwealth · 9 Va. App. 272 - Keech v. Commonwealth · Delawder 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A. Any person who, as a result of driving under the influence in violation of clause (ii), (iii), or (iv) of § 18.2-266 ... unintentionally causes the death of another person, shall be guilty of involuntary manslaughter. B. If, in addition, the conduct of the defendant was so gross, wanton and culpable as to show a reckless disregard for human life, he shall be guilty of aggravated involuntary manslaughter....”
2 later decisions quote this exact passage“The phrase “as a result of driving under the influence ... causes the death” requires proof of a causal connection between the driver’s intoxication and the death of another person. Therefore, even if you find beyond a reasonable doubt that the defendant was driving while intoxicated, he cannot be found guilty of either grade of involuntary manslaughter unless you also find, beyond a reasonable doubt a causal connection between the defendant’s intoxication and the death of Wayne A. Holmes. The causal connection required is a cause “which in the natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury without which the result would not have occurred.””
1 later decision quote this exact passage“In light of the above testimony, we held the evidence was sufficient to prove that Pollard’s intoxication caused him to operate his vehicle in a manner that resulted in [the victim’s] death. The evidence proved that Pollard’s speed and failure to maintain a proper look out contributed to [the victim’s] death. The evidence also proved that Pollard smelled of alcohol, slurred his speech and was unsteady. Thus the proof of intoxication was sufficient to connect Pollard’s speed, failure to brake, and inattention with his “impaired perception, retarded reflexes, and disrupted motor coordination.” Thus, proof of causation has been satisfied.”
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.