28 Va. App. 730 - Pitt v. Commonwealth’s Empirical Analysis
1999
Citation profile
6
cited by 6 later decisions
1
states following
November 2000
most recently cited
6 state decisions
Relationships
Relies on Bruton v. United States · Delaware v. Van Arsdall · Ohio v. Roberts · Pointer v. Texas · 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[O]ther courts generally consider as factors detracting from trustworthiness (1) whether the declarant was being questioned by the police, (observing that the statements were "`given in response to the questions of police, who . , . no doubt knew what they were looking for, and [they] w[ere] not tested in any manner by contemporaneous cross-examination by counsel....'"), (2) "whether the declarant was in police custody when the statement was made," (3) "whether the declarant had a motive to mitigate his own criminal liability," and (4) "whether the declarant made the statement in response to leading questions."”
1 later decision quote this exact passage · from the dissent“In short, the use of corroborating evidence to support a hearsay statement's "particularized guarantees of trustworthiness" would permit admission of a presumptively unreliable statement by boot-strapping on the trustworthiness of other evidence at trial, a result we think at odds with the requirement that hearsay evidence admitting under the Confrontation Clause be so trustworthy that cross-examination of the declarant would be of marginal utility.... Moreover, ... we [decline] to rely on corroborative physical evidence and indeed [have] rejected the "interlock" theory....”
1 later decision quote this exact passage · from the dissent“[S]tatements made in response to police interrogation generally do not have inherent guarantees of reliability and trustworthiness.”
1 later decision quote this exact passage · from the dissent
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.