21 Va. App. 466 - Hancock v. Commonwealth’s Empirical Analysis
1995
Citation profile
16 state decisions
How this case has been cited
Cited by 16 later decisions — most recently July 2020
16 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 Staples v. United States · Powers v. Commonwealth · Clodfelter v. Commonwealth · LaPrade v. Commonwealth · Crisman 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“To support a conviction based upon constructive possession, “the Commonwealth must point to evidence of acts, statements, or conduct of the accused or other facts or circumstances which tend to show that the [accused] was aware of both the presence and character of the [item] and that it was subject to his dominion and control.””
3 later decisions quote this exact passage · from the concurrence“No evidence established that Hancock ever held the firearm, saw it, knew it was present, or exercised any dominion and control over it. See Powers, 227 Va. at 476 , 316 S.E.2d at 740 . The facts established no more than a mere suspicion that the firearm was possessed by Hancock or that he knew the firearm was under the driver’s seat. The evidence must rise beyond “the realm of probability and supposition.” Hall v. Commonwealth, 225 Va. 533, 537 , 303 S.E.2d 903, 905 (1983). “ ‘Circumstances of suspicion, no matter how grave or strong, are not proof of guilt sufficient to support a [guilty] verdict ... beyond a reasonable doubt.’ ” Crisman [v. Commonwealth], 197 Va. [17,] 21, 87 S.E.2d [796,] 799 [ (1955) ] (quoting Powers v. Commonwealth, 182 Va. 669, 676 , 30 S.E.2d 22, 25 (1944)). Proof that the firearm was located close to Hancock was not sufficient to prove the elements of the offense beyond a reasonable doubt. See Jones v. Commonwealth, 17 Va.App. 572 -74, 439 S.E.2d 863, 864 (1994).”
1 later decision quote this exact passage · from the concurrence
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.