319 Pa. Super. 115 - Commonwealth v. Carrillo’s Empirical Analysis
1983
Citation profile
18 state decisions
How this case has been cited
Cited by 18 later decisions — most recently November 2010
18 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 Chapman v. State of California · Bates v. State Bar · Commonwealth Ex Rel. Washington v. Maroney · Davis v. United States · Commonwealth v. Story
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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Numerous cases have contained language in one way or another lending support to the generality that it is at least better practice to appoint a disinterested person as interpreter____ However, a substantial number of cases have recognized that it is at least not necessarily reversible error to appoint a relative or friend of a witness or party to interpret especially where no other competent interpreter is available. * * ‡ * * * Cases throughout the annotation, frequently applying the broadly recognized principle that the appointment of an interpreter rests in the wise discretion of the trial court whose judgment may not be overturned unless abused, or finding an absence of prejudice in the circumstances, have held that no reversible error was committed, by trial courts who appointed as interpreters of non-English speaking witnesses (1) a friend or relative of a witness or victim in a criminal case, ..(2) ...; and (3) a law enforcement officer or other governmental official to interpret for a prosecution witness in a criminal case,____”
1 later decision quote this exact passage · from the dissent“While in the nature of things, a disinterested interpreter is essential to an impartial interpretation of a witness’ testimony, at the same time the trial court is necessarily accorded a wide discretion in determining the fitness of the person called, and the exercise of that discretion will not be disturbed on review in the ab sence of some evidence from which prejudice can be inferred. (Citations omitted) Additionally, as is germane to the case at bar, it has been stated unequivocally that “rulings on the appointment and qualifications of interpreters do not reach constitutional proportions. See Fairbanks v. Cowan, 6 Cir., 551 F.2d 97, 99 . Whatever problems there may be with the testimony of [an interpreter] go to the sufficiency of the evidence.” ... Soap v. Carter, 632 F.2d 872, 874-75 (10th Cir.1980), cert. denied, 451 U.S. 939 , 101 S.Ct. 2021 , 68 L.Ed.2d 327 (1981).”
1 later decision quote this exact passage · from the dissent“to adopt a per se rule that there is an inherent bias, and a violation of due process rights, whenever a police officer is called upon to serve as a defendant's interpreter at an interrogation.”
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.