31 Va. App. 113 - Conrad v. Commonwealth’s Empirical Analysis
1999
Citation profile
2 federal appellate · 23 state decisions
How this case has been cited
Cited by 26 later decisions — most recently July 2020 · most notably 41 Va. App. 539 - Banks v. Commonwealth (2003), 42 Va. App. 347 - Kelly v. Commonwealth (2004)
2 federal appellate · 23 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 4 Va. App. 438 - Martin v. Commonwealth · Derr v. Commonwealth · Griffin v. Shively · 26 Va. App. 154 - Juares v. Commonwealth · 26 Va. App. 335 - Watkins 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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Criminal negligence ... is judged under an objective standard and, therefore, may be found to exist where the offender either knew or should have known the probable results of his acts. See Keech [v. Commonwealth], 9 Va.App. [272,] 279, 386 S.E.2d [813,] 817 [(1989)] (citing Bell v. Commonwealth, 170 Va. 597, 611-12 , 195 S.E. 675, 681 (1938)). Thus, criminal negligence “ ‘is acting consciously in disregard of another person’s rights or acting with reckless indifference to the consequences, with the defendant aware, from his knowledge of existing circumstances and conditions, that his conduct probably would cause injury to another.’ ” Tubman [v. Commonwealth], 3 Va.App. [267,] 271, 348 S.E.2d [871,] 873 [(1986)](emphasis added) (quoting Griffin [v. Shively], 227 Va. [317,] 321, 315 S.E.2d [210,] 213 [(1984)]; Friedman v. Jordan, 166 Va. 65, 68 , 184 S.E. 186, 187 (1936)).”
2 later decisions quote this exact passage“a conviction of involuntary manslaughter involving the operation of a motor vehicle can be supported when the conduct of the driver constitutes a great departure from that of a reasonable person (gross, wanton or willful conduct) which creates a great risk of injury to others and where by the application of an objective standard the accused should have realized the risk created by his conduct.”
1 later decision quote this exact passage“[i]f [the appellant] had been operating his vehicle for a number of hours in a tired and sleepy condition, or while in such a state undertook a trip of such a substantial distance or time that he should have known he might fall asleep, the evidence might support a finding that he was acting in reckless disregard for human life.”
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.