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← 404 Pa. Super. 504 - Commonwealth v. Gettemy

404 Pa. Super. 504 - Commonwealth v. Gettemy’s Empirical Analysis

1991

Citation profile

21
cited by 21 later decisions
2
states following
February 2022
most recently cited

21 state decisions

How this case has been cited

Cited by 21 later decisions — most recently February 2022

21 state decisions

1001991200020102020decided

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 Commonwealth v. Wojdak · Commonwealth v. Prado · 272 Pa. Super. 411 - Commonwealth v. Carter · 196 N.J. Super. 392 - State v. D'ADDARIO

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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““A person commits a misdemeanor of the second degree if, believing that an official proceeding or investigation is pending or about to be instituted, he: “(1) alters, destroys, conceals or removes any record, document or thing with intent to impair its verity or availability in such proceeding or investigation;...””
    2 later decisions quote this exact passage
  2. “(a) Offense defined.—A person commits an offense if, with intent to hinder the apprehension, prosecution, conviction or punishment of another for crime, he: (5) volunteers false information to a law enforcement officer.”
    2 later decisions quote this exact passage
  3. “[T]he courts of New Jersey were faced with this exact issue in State v. D'Addario, 196 N.J.Super. 392 , 482 A.2d 961 (1984). The New Jersey Superior Court stated that this definition, particularly the emphasized language, supports the conclusion that the meaning of ‘volunteer’ as used in N.J.S.A. 2C:29-3a(7), is that the accused must take the initiative in giving false information. We point out that the wording of the New Jersey statute is identical to that of the Pennsylvania statute, as both statutes are derived from the Model Penal Code. The court in D’Addario, stated that the statute applied only to those persons who take the initiative in supplying false information to law enforcement officials. Recognizing that we are not bound by the decisions of a sister state, we, nevertheless find the reasoning of the New Jersey Court to be persuasive. The facts of the instant case make it clear that Appellee did not take the initiative in supplying false information to the law enforcement officers. Her answers, misleading as they were, were given in response to the officers questions. Additionally, the Official Comment to 18 Pa.C.S. § 5105 states that this section is derived from Section 242.3 of the Model Penal Code. The comment to this section provides: Paragraph (5) prohibits volunteering false information to the law enforcement authorities. Mere failure to report a crime is not proscribed by this section. Neither is giving misleading or even false answers to inquiries initiated”
    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.