Goins v. Commonwealth’s Empirical Analysis
1977
Citation profile
48 state decisions
How this case has been cited
Cited by 48 later decisions — most recently August 2011 · most notably 4 Va. App. 438 - Martin v. Commonwealth (1987), Goins v. Commonwealth (1996)
48 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 Chapman v. State of California · Higginbotham v. Commonwealth · Comfort v. California · Nicholaou v. Harrington · Van Dyke 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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“possess at least the following essential elements: (1) The statement or declaration made must relate to the main event and must explain, elucidate, or in some way characterize that event; (2) it must be a natural declaration or statement growing out of the event, and not a mere narrative of a past, completed affair; (3) it must be a statement of fact and not the mere expression of an opinion; (4) it must be a spontaneous or instinctive utterance of thought, dominated or evoked by the transaction or occurrence itself, and not the product of premeditation, reflection, or design; (5) while the declaration or statement need not be coincident or contemporaneous with the occurrence of the event, it must be made at such time and under such circumstances as will exclude the presumption that it is the result of deliberation; and (6) it must appear that the declaration or statement was made by one who either participated in the transaction or witnessed the act or fact concerning which the declaration or statement was made.”
1 later decision quote this exact passage · from the majority“Whether a hearsay statement is an excited utterance is not determined solely by the lapse of time between the startling event and the declaration. Instead, the lapse of time is but one circumstance to consider when determining whether the declarant’s statement was prompted by a startling event, and not the product of premeditation, reflection, or design.”
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.