Sullivan v. Commonwealth’s Empirical Analysis

Citation profile

31 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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Under Virginia law, upon proof of a breaking and entering and a theft of goods, and if the evidence warrants an inference that the breaking and entering and the theft were committed at the same time by the same person and as a part of the same transaction, ‘the exclusive possession of the stolen goods shortly thereafter, unexplained or falsely denied, has the same efficiency to give rise to an inference that the possessor is guilty of the breaking and entering as to an inference that he is guilty of the larceny’. Drinkard v. Commonwealth, 163 Va. 1074, 1083 , 178 S.E. 25, 28 (1935); Hawley v. Commonwealth, 206 Va. 479 , 144 S.E.2d 314 (1965); Fout v. Commonwealth, 199 Va. 184 , 98 S.E.2d 817 (1957).””

   3 later decisions quote this exact passage · from the majority
   e.g. 4 Va. App. 248 - Bright v. Commonwealth · 55 Va. App. 59 - Lunsford v. Commonwealth

2. “[I]n Sullivan ... the evidence warranted an inference that the breaking and entering and theft were committed at the same time by the same person and as a part of the same transaction, so that the exclusive possession of the recently stolen card ... could properly give rise to the inference that the possessor [the defendant] had committed the burglary. [The Supreme Court] also held that recency of possession is an issue to be determined by the trier of fact.”

   1 later decision quote this exact passage · from the majority
   e.g. 20 Va. App. 133 - Sandoval v. Commonwealth