221 Pa. Super. 410 - Commonwealth v. DeVaughn’s Empirical Analysis
1972
Citation profile
10
cited by 10 later decisions
1
states following
September 2002
most recently cited
7 state decisions
Relationships
Relies on North Carolina v. Pearce · Ashe v. Swenson · Benton v. Maryland · Green v. United States · Sealfon v. United States
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the rule of collateral estoppel in criminal cases is not to be applied with the hypertechnical and archaic approach of a 19th century pleading book, but with realism and rationality. Where a previous judgment of acquittal was based upon a general verdict, as is usually the case, this approach requires a court to `examine the record of a prior proceeding, taking into account the pleadings, evidence, charge, and other relevant matter, and conclude whether a rational jury could have grounded its verdict upon an issue other than that which the defendant seeks to foreclose from consideration.' [Footnote omitted]. The inquiry `must be set in a practical frame and viewed with an eye to all the circumstances of the proceedings.' [Citation omitted]. Any test more technically restrictive would, of course, simply amount to a rejection of the rule of collateral estoppel in criminal proceedings, at least in every case where the first judgment was based upon a general verdict of acquittal.”
1 later decision quote this exact passage“without a scintilla of evidence that decedent died as a result of some other cause than the [fire], a rational jury cannot be presumed to have found tht the decedent died from anything but those”
1 later decision quote this exact passage“whether the jury in [appellee's] first trial for felonious homicide could have rationally grounded its verdict of acquittal on any other issue than [appellee's] nonparticipation in the [arson].”
1 later decision 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.