Commonwealth v. Walton’s Empirical Analysis
1979
Citation profile
2 federal appellate · 90 state decisions
How this case has been cited
Cited by 95 later decisions — most recently January 2026 · most notably United States v. Lemire (1983), Coles v. State (1981)
2 federal appellate · 90 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 Commonwealth v. Walker · Commonwealth v. Kates · Sherwood v. Elgart · Commonwealth v. Vivian · Commonwealth v. Walls
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 95 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) General rule. — Upon conviction for any crime wherein property has been stolen, converted or' otherwise unlawfully obtained, or its value substantially decreased as a direct result of the crime, or wherein the victim suffered personal injury directly resulting from the crime, the offender shall be sentenced to make restitution in addition to the punishment prescribed therefor. (b) Condition of probation or parole. — Whenever restitution has been ordered pursuant to subsection (a) and the offender has been placed on probation or parole, his compliance with such order may be made -a condition of such probation or parole. (c) Mandatory restitution.— (1) The court shall order full restitution: (i)Regardless of the current financial resources of the defendant, so as to provide the victim with the fullest compensation for the loss. The court shall not reduce a restitution award by any amount that the victim has received from the Crime Victim’s Compensation Board or other governmental agency but shall order the defendant to pay any restitution ordered for loss previously compensated by the board to the Crime Victim’s Compensation Fund or other designated account when the claim involves a government agency in addition to or in place of the board. The court shall not reduce a restitution award by any amount that the victim has received from an insurance company but shall order the defendant to pay any restitution ordered for loss previously compensated by an insurance company to t”
5 later decisions quote this exact passage · from the majority“(a) General Rule. — In imposing an order of probation the court shall specify at the time of sentencing the length of any term during which the defendant is to be supervised, which term may not exceed the maximum term for which the defendant could be confined, and the authority that shall conduct the supervision. (b) Conditions generally. — The court shall attach such of the reasonable conditions authorized by subsection (c) of this section as it deems necessary to insure or assist the defendant in leading a law-abiding life. (c) Specific conditions. — The court may as a condition of its order require the defendant: (8) To make restitution of the fruits of his crime or to make reparations, in an amount he can afford to pay, for the loss or damage caused thereby.”
3 later decisions quote this exact passage · from the majority“[Conditions of probation, though significant restrictions on the offender’s freedom, are primarily aimed at effecting, as a constructive alternative to imprisonment, his rehabilitation and réintegration into society as a law-abiding citizen; courts therefore are traditionally and properly invested with a broader measure of discretion in fash ioning conditions of probation appropriate to the circumstances of the individual case.”
3 later decisions 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.