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← 216 VA 820 - Dillard v. Commonwealth

Dillard v. Commonwealth’s Empirical Analysis

1976

Citation profile

40
cited by 40 later decisions
2
states following
August 2015
most recently cited

40 state decisions

How this case has been cited

Cited by 40 later decisions — most recently August 2015 · most notably 164 W. Va. 216 - State v. Vance (1980), State v. Sarracino (1998)

40 state decisions

14019761980199020002010decided

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 Clinton v. Commonwealth · Benson v. Commonwealth · Clinton v. Virginia · Blount v. Commonwealth · Largin 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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““The corroborative evidence, standing alone,' need not be sufficient either to support a conviction or to establish all the essential elements of an offense. If those were the requirements, and the Commonwealth had at hand independent evidence sufficient to satisfy them, then the need to use accomplice testimony would not arise. * * * “Where, therefore, the testimony of an accomplice is corroborated in material facts which tend to connect the accused with the crime, sufficient to warrant the jury in crediting the truth of the accomplice’s testimony, it is not error to refuse a cautionary instruction. This rule applies even though the corroborative evidence falls short of constituting ‘independent evidence which supports the alleged ultimate fact’ that the accused committed the offense charged.” 216 Va. at 823-24 , 224 S.E.2d at 140 .”
    4 later decisions quote this exact passage · from the majority
  2. ““[T]he test in determining whether [a cautionary accomplice instruction] should be granted is: does the evidence support the instruction? Cautionary accomplice instructions . .. deal with a lack of evidence, evidence of a corroborative nature. The test, therefore, in determining whether a cautionary instruction should be granted becomes this: is corroborative evidence lacking? If it is, the instruction should be granted; if it is not lacking, the instruction should be refused .. ..” 216 Va. at 822 , 224 S.E.2d at 139 .”
    3 later decisions quote this exact passage · from the majority
  3. “Barry Jones has testified that he was an accomplice in the commission of the crime charged in the indictment. While you may find your verdict upon his uncorroborated testimony, you should consider such testimony with great care and you are cautioned as to the danger of convicting the defendant upon the uncorroborated testimony of an accomplice. Nevertheless, if you are satisfied from the evidence of the guilt of the defendant beyond a reasonable doubt, you may convict the defendant on the uncorroborated testimony of a single accomplice.”
    1 later decision quote this exact passage · from the majority

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.