399 Pa. Super. 277 - Commonwealth v. Nieves’s Empirical Analysis
1990
Citation profile
36 state decisions
How this case has been cited
Cited by 36 later decisions — most recently January 2026 · most notably 413 Pa. Super. 599 - Commonwealth v. Wall (1992), 432 Pa. Super. 523 - Commonwealth v. Gaddis (1994)
36 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 Poola v. UNEMP. COMP. BD. OF REVIEW · Commonwealth v. Durst · Commonwealth v. Billa · Haas v. Kasnot · 337 Pa. Super. 548 - Commonwealth v. Black
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“At common law evidence of a female rape complainant’s general reputation for morality and chastity was deemed admissible on the issue of consent. The result of this common law rule was notorious abuse of victim witnesses by aggressive defense counsel who essentially put the victim on trial. In response to such unjustifiable abuses, the federal government and states enacted statutes known as Rape Shield laws. Rape Shield laws were intended to end the abuses fostered by the common law rule by limiting the harassing and embarrassing inquiries of defense counsel into irrelevant prior sexual conduct of sexual assault complainants.”
2 later decisions quote this exact passage · from the concurrence“To that end, limited exceptions to the broad exclusion of the rape shield law have arisen to demonstrate the rape shield law “will bow to a defendant’s right to cross-examine when a specific proffer demonstrates that the proposed inquiry is intended to elicit relevant evidence, which is more probative than prejudicial, and which is not cumulative of other evidence available without encroaching upon Rape Shield law protections.””
2 later decisions quote this exact passage · from the concurrence“In determining whether the application of the Rape Shield Law violates a defendant’s constitutional rights to confront and cross-examine witnesses against him, this court has recently held: In Pennsylvania, we have come to resolve this question through a relatively elaborate procedure which is designed to ensure that no evidence of the victim’s sexual history is introduced unless and until it can be established that to exclude such evidence would lay victim to the very raison d’etre of the trial itself: the pursuit of truth. The process begins with the defendant submitting a specific proffer to the court of exactly what evidence he or she seeks to admit and precisely why it is relevant to the defense. This procedure forces the defendant to frame the precise issues and interests involved, and prevents him or her from embarking upon ‘fishing expedition style intrusions on Rape Shield Law protections.’ Where the proffer is but vague and conjectural, evidence of the victim’s past sexual conduct will be excluded and no further inquiry need be entertained.”
1 later decision quote this exact passage · from the majority
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.