24 Va. App. 345 - Randolph v. Commonwealth’s Empirical Analysis
1997
Citation profile
22 state decisions
How this case has been cited
Cited by 22 later decisions — most recently August 2011
22 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 Bruton v. United States · Ohio v. Roberts · Pointer v. Texas · Bourjaily v. United States · Richardson v. Marsh
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In Virginia, for a declaration against penal interest to be admissible, it must meet the following requirements: (1) the declarant must be “unavailable to testify at trial,” (2) the statement must be against the declarant’s interest at the time it was made; and (3) the declarant must be aware at the time the statement is made that it is against his or her interest to make it. While it is settled ... that a declaration against penal interest is recognized as an exception to the hearsay rule, “ ‘such a declaration made out of court by ... [an] unavailable witness is admissible only upon a showing that the declaration is reliable.’ ””
1 later decision quote this exact passage““ ‘once it has been established that a third-party confession has been made, the crucial issue is whether the content of the confession is trustworthy. And determination of this issue turns upon whether ... the case is one where “there is anything substantial other than the bare confession to connect the declarant with the crime.” ’ ””
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.