24 Va. App. 279 - Sparks v. Commonwealth’s Empirical Analysis
1997
Citation profile
15 state decisions
How this case has been cited
Cited by 15 later decisions — most recently July 2018
15 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 14 Va. App. 454 - Hooker v. Commonwealth · Neeley v. Johnson · "Automatic" Sprinkler Corp. of America v. Coley & Petersen, Inc. · Ford Motor Co. v. Phelps · Kettler & Scott, Inc. v. Earth Technology Companies
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[6,7] The business records exception to the hearsay rale allows introduction “into evidence of verified regular [business] entries without requiring proof from the original observers or record keepers.” Neeley v. Johnson, 215 Va. 565, 571 , 211 S.E.2d 100, 106 (1975)----“Admission of such evidence is conditioned ... on proof that the document comes from the proper custodian and that it is a record kept in the ordinary course of business made contemporaneously with the event by persons having the duty to keep a true record.” “Automatic” Sprinkler [Corp. of America v. Coley & Petersen, Inc., 219 Va. 781, 793 , 250 S.E.2d 765, 773 (1979)]....”
4 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.