21 Va. App. 161 - Graves v. Commonwealth’s Empirical Analysis
1995
Citation profile
2 federal appellate · 19 state decisions
How this case has been cited
Cited by 21 later decisions — most recently October 2016
2 federal appellate · 19 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 State v. White · Mason v. Commonwealth · Johnson v. Commonwealth · Commonwealth v. Jones · Jones 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Because the [robbery] indictment against Graves did not set forth allegations of value or of theft from the person, it did not charge grand larceny from the person. Therefore, grand larceny from the person was not a lesser offense included within the robbery specification of the indictment.”
2 later decisions quote this exact passage“At common law property was stolen “from the person” of another even if it was only “in the presence” of the person at the time it was stolen.... “Property is stolen ‘from the person’ if it was under the protection of the person ... although not actually ‘attached’ to him.... As said by Coke in the 1600’s: ‘for that which is taken in his presence, is in law taken from his person.’ ””
1 later decision quote this exact passage · from the dissent“A lesser included offense is necessarily charged by implication in an indictment for a greater offense and necessarily proven by the proof of the greater offense____A crime that is not a necessarily lesser included offense, on the other hand, is not charged by implication and is not necessarily proved by proof of the greater offense.”
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.