Commonwealth v. Dalton’s Empirical Analysis
2000
Citation profile
40 state decisions
How this case has been cited
Cited by 46 later decisions — most recently November 2021 · most notably 41 Va. App. 752 - Edwards v. Commonwealth (2003), Thomas v. Com. (2010)
40 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 Holm v. United States · Frye v. Commonwealth · Satcher v. Commonwealth · Jones v. Commonwealth · McClung 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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[A]n accused cannot be convicted of a crime that has not been charged, unless the crime is a lesser-included offense of the crime charged. Thus, neither the Commonwealth nor an accused is entitled to a jury instruction on an offense not charged, unless the offense is a lesser-included offense of the charged offense.””
3 later decisions quote this exact passage · from the majority“The Due Process Clauses of the Constitution of the United States and the Constitution of Virginia mandate that an accused be given proper notification of the charges against him. U.S. Const. amend. XIV; Va. Const. art. 1, § 8.Code § 19.2-220 provides, in pertinent part, that an indictment shall be “a plain, concise and definite written statement, (1) naming the accused, (2) describing the offense charged, (3) identifying the county, city or town in which the accused committed the offense, and (4) reciting that the accused committed the offense on or about a certain date.” An indictment, to be sufficient, must give an accused notice of the nature and character of the charged offense so the accused can make his defense. Satcher v. Commonwealth, 244 Va. 220, 231 , 421 S.E.2d 821, 828 (1992), cert. denied, 507 U.S. 933 , 113 S.Ct. 1319 , 122 L.Ed.2d 705 (1993). It is firmly established, therefore, that an accused cannot be convicted of a crime that has not been charged, unless the crime is a lesser-included offense of the crime charged.”
2 later decisions quote this exact passage · from the majority“before a defendant can be tried and convicted of being an accessory after the fact, he must be charged with that offense.”
2 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.