3 Va. App. 474 - Clark v. Commonwealth’s Empirical Analysis
1986
Citation profile
8 state decisions
How this case has been cited
Cited by 8 later decisions — most recently July 2010
8 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 Clozza v. Commonwealth · Doe v. Thomas · Thims v. Commonwealth · Goins v. Commonwealth · Nicholaou v. Harrington
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although not controlling, the lapse of time between the “startling event” and a declaration offered in evidence is relevant to a determination whether the declaration was spontaneous and instinctive, or premeditated and deliberative. It is also relevant to consider whether the declarant made an exclamation impulsively on his own initiative, or a statement in response to a question. And a further factor in the trustworthiness equation is whether the statement was an admission against interest or a self-serving declaration.”
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.