Makarov v. Commonwealth’s Empirical Analysis
1976
Citation profile
41 state decisions
How this case has been cited
Cited by 43 later decisions — most recently August 2013 · most notably Esteban v. Commonwealth (2003), State v. Carpenter (1980)
41 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
Applies 28 U.S.C. § 2007
Relies on Maye v. Commonwealth · Rinehart & Dennis Co. v. McArthur · Overstreet v. Commonwealth · West v. West · Kidd v. Virginia Safe Deposit & Trust Corp.
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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“There, we construed a statute specifically dealing with larceny, a crime which presupposes a mens rea. But here [a case making the failure to pay wages a crime] the statute on its face deals with a naked civil debt and we cannot say the General Assembly implicitly meant to include proof of an intent to defraud as an essential element of the offense.”
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.