29 Va. App. 199 - Brown v. Commonwealth’s Empirical Analysis
1999
Citation profile
16 state decisions
How this case has been cited
Cited by 16 later decisions — most recently January 2016
16 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 Brewster v. Derwinski · Connors v. United States · Gray v. Commonwealth · Breeden v. Commonwealth · Stockton 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Brown's counsel sought to question Doe about prior testimony, not her prior conduct. Furthermore, the testimony sought was not about sexual conduct.”
2 later decisions quote this exact passage“In Lampley , the defendant argued that the stepdaughter’s previous complaint of sexual abuse was relevant to show “... how she benefited [sic] from the prior complaint.” [859 S.W.2d] at 910. The evidence showed that the prior abuse complaint resulted in removal of the subject of the complaint from the stepdaughter’s house. See id. at 911 . The defendant argued that the stepdaughter did not like him and “accusing him of sexual molestation was a way of getting him out of her home.” Id. Therefore, the defendant argued that he should have been allowed to question his stepdaughter about the prior complaint to determine if she had any possible motive to fabricate the complaint against him. See id. The Missouri Court of Appeals reversed his convictions, holding that the defendant “never indicated an intention to go into prior sexual conduct ... [and it was] not the stated subject of cross-examination.” Id. The court held that a limited inquiry about the prior complaint would have been permissible if it was confined to “show motive to fabricate and never implicate [the statute].” Id. at 912 . Therefore, “the trial court view that reference to the prior incident is ‘totally irrelevant’ is patently wrong.” Id. at 912 .”
1 later decision quote this exact passage“A. In prosecutions under this article ... evidence of the complaining witness’s unchaste character or prior sexual conduct shall not be admitted. Unless the complaining witness voluntarily agrees otherwise, evidence of specific instances of his or her prior sexual conduct shall be admitted only if it is relevant and is: 1. Evidence offered to provide an alternative explanation for physical evidence of the offense charged which is introduced by the prosecution, limited to evidence designed to explain the presence of semen, pregnancy, disease, or physical injury to the complaining witness’s intimate parts; or C. Evidence described in subsections A and B of this section shall not be admitted and may not be referred to at any preliminary hearing or trial until the court first determines the admissibility of that evidence at an evidentiary hearing to be held before the evidence is introduced at such preliminary hearing or trial....”
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.