Fitzgerald v. Commonwealth’s Empirical Analysis
1984
Citation profile
39 state decisions
How this case has been cited
Cited by 40 later decisions — most recently February 2014 · most notably 28 Va. App. 187 - Timbers v. Commonwealth (1998), 14 Va. App. 988 - Campbell v. Commonwealth (1992)
39 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 In re Disbarment of Harris · Bullock v. Commonwealth · Denis v. Commonwealth · Harrison v. Commonwealth · Timmons v. State
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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[It] is the false making or materially altering with intent to defraud, of any writing which, if genuine, might apparently be of legal efficacy, or the foundation of legal liability.”
2 later decisions quote this exact passage · from the majority“Although the evidence here repels the inference that [the accused] personally forged the name of the maker, it is entirely consistent with the inference that [s]he procured it to be done. It has been the law of Virginia for more than a century and a half that one who procures the forgery of an instrument is an accessory before the fact if he was absent when the writing was forged, or a principal in the second degree if he was present. The distinction is of no consequence, because his guilt is the same, and he is subject to the same punishment, in either event.”
1 later decision quote this exact passage · from the majority“The fact that an instrument was forged, made payable to the defendant, and endorsed by him, is sufficient evidence of the defendant’s intent to defraud the drawee---- More- over, “[possession of a forged check by an accused, which he claims as a payee, is prima facie evidence that he either forged the instrument or procured it to be forged.” Such a prima facie showing of guilt does not rise to the level of a conclusive presumption, and it may be rebutted, but ... will support a verdict of guilty if the jury so finds.”
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.