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← 428 MASS 24 - Commonwealth v. Whelton

Commonwealth v. Whelton’s Empirical Analysis

1998

Citation profile

82
cited by 82 later decisions
3
states following
August 2018
most recently cited

2 federal appellate · 80 state decisions

How this case has been cited

Cited by 82 later decisions — most recently August 2018 · most notably Commonwealth v. Alphas (1999), Commonwealth v. Gonsalves (2005)

2 federal appellate · 80 state decisions

470199820002010decided

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 California v. Green · White v. Illinois · Penn Central Transportation Co. v. New York City · Commonwealth v. Latimore · Commonwealth v. Durling

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

  1. “We see no reason to impose an unavailability requirement on reliable evidence.... We conclude that art. 12, like the Sixth Amendment to the United States Constitution, does not require a showing that the declarant is unavailable to testify at trial before a statement is admitted under the spontaneous utterance exception to the rule against hearsay.”
    1 later decision quote this exact passage
  2. “utterance was spontaneous to a degree which reasonably negated premeditation or possible fabrication and if it tended to qualify, characterize and explain the underlying event.”
    1 later decision quote this exact passage
  3. “under the influence of the exciting event”
    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.