Chichester v. Commonwealth’s Empirical Analysis
1994
Citation profile
3 federal appellate · 58 state decisions
How this case has been cited
Cited by 61 later decisions — most recently September 2017 · most notably Goins v. Commonwealth (1996), Johnson v. Commonwealth (2000)
3 federal appellate · 58 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 Batson v. Kentucky · Hernandez v. New York · Powers v. Ohio · Taylor v. Louisiana · National Union Fire Insurance v. Helfand
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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[O]ne of the issues upon which “other crimes” evidence may be admitted is that of the perpetrator’s identity, or criminal agency, where that has been disputed. Proof of modus operandi is competent evidence where there is a disputed issue of identity. [E]vidence of other crimes, to qualify for admission as proof of modus operandi, need not bear such an exact resemblance to the crime on trial as to constitute a “signature.” Rather, it is sufficient if the other crimes bear a “singular strong resemblance to the pattern of the offense charged.” That test is met where the other incidents are “sufficiently idiosyncratic to permit an inference of pattern for purposes of proof,” thus tending to establish the probability of a common perpetrator. If the evidence of other crimes bears sufficient marks of similarity to the crime charged to establish that the defendant is probably the common perpetrator, that evidence is relevant and admissible if its probative value outweighs its prejudicial effect ... The trial court, in the exercise of its sound discretion, must decide which of these competing considerations outweighs the other. Unless that discretion has been clearly abused, we will affirm the trial court’s decision on this issue.”
4 later decisions quote this exact passage · from the majority“Both robberies occurred within nine days and in close geographic proximity to each other; both robbers were black, one was taller than the other, both were armed; both robberies appeared to have been carefully planned to minimize the victims’ opportunity to identify the robbers; both robbers wore masks and gloves; on each occasion, the taller man retrieved the spent cartridge after firing his gun; and, in both robberies, the robbers fled from the scene on foot, rather than in a vehicle, to minimize the possibility of its identification. Further, each robber appeared to be familiar with the premises and the role he was to play in the crimes. In both instances, the shorter man immediately went behind the counter to get the money from the cash register....”
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.