21 Va. App. 482 - Castillo v. Commonwealth’s Empirical Analysis

Citation profile

22 state decisions

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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “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
   e.g. 32 Va. App. 616 - Hall v. Commonwealth

2. “A. Any person who, as a result of driving under the influence in violation of subdivision (ii), (iii), or (iv) of [Code] § 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, a felony punishable by a term of imprisonment of not less than one nor more than twenty years, one year of which shall be a mandatory, minimum term of imprisonment.”

   1 later decision quote this exact passage
   e.g. 32 Va. App. 616 - Hall v. Commonwealth

3. “Any person ... who operates a motor vehicle upon a highway ... in this Commonwealth shall be deemed thereby, as a condition of such operation, to have consented to have samples of his blood, breath, or both blood and breath taken for a chemical test to determine the alcohol, drug, or both alcohol and drug content of his blood, if he is arrested for violation of § 18.2-266 or § 18.2-266.1 or of a similar ordinance within two hours of the alleged offense.”

   1 later decision quote this exact passage
   e.g. 32 Va. App. 228 - Smith v. Commonwealth