Gallimore v. Commonwealth’s Empirical Analysis
1993
Citation profile
5 federal appellate · 32 state decisions
How this case has been cited
Cited by 41 later decisions — most recently December 2017 · most notably Commonwealth v. Jenkins (1998), 41 Va. App. 539 - Banks v. Commonwealth (2003)
5 federal appellate · 32 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 Cable v. Commonwealth · Hubbard v. Murray · Maroulis v. Elliott · Bell v. Commonwealth · Metro MacHine Corp. v. Mizenko
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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]here can be more than one proximate cause [of an incident] and liability attaches to each person whose negligent act results in the victim’s injury or death. Maroulis v. Elliott, 207 Va. 503, 510 , 151 S.E.2d 339, 344 (1966). To be an intervening cause ... [an incident] must have been an event which [the defendant] could not have foreseen. “An intervening act which is reasonably foreseeable cannot be relied upon as breaking the chain of causal connection between an original act of negligence and subsequent injury.” Delawder v. Commonwealth, 214 Va. 55, 58 , 196 S.E.2d 913, 915 (1973). Furthermore, an intervening event, even if a cause of the harm, does not operate to exempt a defendant from liability if the intervening event was put into operation by the defendant’s negligent acts. Baxley v. Fischer, 204 Va. 792, 798 , 134 S.E.2d 291, 295 (1964).”
3 later decisions quote this exact passage · from the majority“a reckless or indifferent disregard of the rights of others, under circumstances reasonably calculated to produce injury, or which make it not improbable that injury will be occasioned, and the offender knows, or is charged with the knowledge of, the probable result of his acts.”
3 later decisions quote this exact passage · from the majority“allows a defendant not present at the commission of the crime to be convicted as a principal in the first degree, if the defendant engaged in actions which caused the actual perpetrator to commit the crime as an innocent agent of the defendant. The innocent agent is “innocent” because he or she is a child, or is mentally incompetent, or otherwise does not have the requisite criminal state of mind.”
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.