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← 423 MASS 99 - Commonwealth v. Jones

Commonwealth v. Jones’s Empirical Analysis

1996

Citation profile

62
cited by 62 later decisions
6
states following
November 2020
most recently cited

62 state decisions

How this case has been cited

Cited by 62 later decisions — most recently November 2020 · most notably Commonwealth v. Crayton (2014), Commonwealth v. Silva-Santiago (2009)

62 state decisions

3401996200020102020decided

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 Miranda v. State of Arizona Vignera · United States v. Wade · Neil v. Biggers · Stovall v. Denno · Manson v. Brathwaite

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

  1. “Eyewitness identification of a person whom the witness had never seen before the crime or other incident presents a substantial risk of misidentification and increases the chance of a conviction of an innocent defendant. In Commonwealth v. Johnson, supra, we noted that, “the vagaries of eyewitness identification are well-known; the annals of criminal law are rife with instances of mistaken identification.” Id, at 466 quoting United States v. Wade, 388 U.S. 218, 228 (1967), and citing numerous authorities. Id. at 467-68 n.9. The Supreme Court has de-emphasized the role of deterring police misconduct in the analysis of suggestive confrontations to focus more on nonreliabilify as the justification for the exclusion of an identification that may have been influenced by a suggestive confrontation. See Neil v. Biggers, 409 U.S. 188, 198 (1972) (“[i]t is the likelihood of misidentification which violates a defendant’s right to due process, and it is this which was the basis for the exclusion of evidence”); Manson v. Brathwaite, 432 U.S. 98, 111-12 (1977). We need not base our decision on constitutional grounds. Common law principles of fairness dictate that an unreliable identification arising from the especially suggestive circumstances of this case should not be admitted. This encounter was not a casual confrontation in neutral surroundings, such as occur through the media. See, e.g., Commonwealth v. Colon-Cruz, 408 Mass. 533, 542 (1990).”
    1 later decision quote this exact passage · from the dissent
  2. “its admissibility 'should not turn on whether government agents had a hand in causing the confrontation,'”
    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.