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← 221 Pa. Super. 410 - Commonwealth v. DeVaughn

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.

  1. “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
  2. “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
  3. “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.