Carter v. Commonwealth’s Empirical Analysis
1986
Citation profile
31 state decisions
How this case has been cited
Cited by 33 later decisions — most recently August 2021 · most notably 11 Va. App. 535 - Rollston v. Commonwealth (1991), Vasquez v. Commonwealth (2016)
31 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 LeVasseur v. Commonwealth · Levasseur v. Wainwright · United States v. Douglass · Ansell v. Commonwealth · Hatcher 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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a]n incidental probable consequence of such a shared intent was the use of a weapon, including a firearm if one should be at hand. In such circumstances, the law is well settled in Virginia that each co-actor is responsible for the acts of the others, and may not interpose ... personal lack of intent as a defense.”
6 later decisions quote this exact passage · from the majority““[a]ll those who assemble themselves together with an intent to commit a wrongful act, the execution whereof make probable, in the nature of things, a crime not specifically designed, but incidental to that which was the object of the confederacy, are responsible for such incidental crime.... Hence, it is not necessary that the crime should be a part of the original design; it is enough if it be one of the incidental probable consequences of the execution of that design, and should appear at the moment to one of the participants to be expedient for the common purpose.””
4 later decisions quote this exact passage · from the majority“[i]f there is concert of action with the resulting crime one of its incidental probable consequences, then whether such crime was originally contemplated or not, all who participate in any way in bringing it about are equally answerable and bound by the acts of every other person connected with the consummation of such resulting crime.”
3 later decisions 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.