Gray v. Commonwealth’s Empirical Analysis
1980
Citation profile
41 state decisions
How this case has been cited
Cited by 41 later decisions — most recently November 2009 · most notably 13 Va. App. 333 - Myrick v. Commonwealth (1991), 3 Va. App. 657 - Allen v. Commonwealth (1987)
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
Relies on Burks v. United States · Greene v. Massey · Ansell v. Commonwealth · Sydnor Pump & Well Co. v. Taylor · Jordan v. Town of South Boston
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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A report of analysis duly attested by the person performing such analysis or examination in any laboratory operated by the Division of Consolidated Laboratory Services or the Division of Forensic Science shall be prima facie evidence in a criminal or civil proceeding as to the custody of the material described therein from the time such material is received by an authorized agent of either Division until such material is released subsequent to such analysis or examination.”
6 later decisions quote this exact passage · from the dissent“[Code § 19.2-187] deals with criminal matters, and it undertakes to make admissible evidence which otherwise might be subject to a valid hearsay objection. Thus, the statute should be construed strictly against the Commonwealth and in favor of the accused. This rule of construction is particularly applicable to the filing requirements of § 19.2-187; these requirements are contained in a proviso to the Code section. The proviso serves to limit and restrain what precedes it in the statute.”
5 later decisions quote this exact passage“The statute does not provide that it shall suffice if, in lieu of filing with the clerk, a copy of the certificate is furnished to defense counsel in advance of trial; neither does the statute provide that filing with the clerk three, rather than seven, days prior to trial shall be sufficient unless an accused can show prejudice resulting from the failure earlier to file the certificate. For this court to read these provisions into § 19.2-187 would be to construe the statute strictly against the accused and in favor of the Commonwealth, a result clearly contrary to the applicable rule of construction.”
3 later decisions quote this exact passage
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.