5 Va. App. 188 - Evans-Smith v. Commonwealth’s Empirical Analysis
1987
Citation profile
132 state decisions
How this case has been cited
Cited by 132 later decisions — most recently June 2019 · most notably Riner v. Com. (2004), MacKall v. Commonwealth (1988)
132 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 Rideout v. United States · Shepard v. United States · Harryman v. Estelle · Thompson v. Commonwealth · Karnes v. Commonwealth
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 132 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The test in a criminal case is not whether the jurors were actually prejudiced by the extraneous matter but whether they might have been so prejudiced. If they might have been prejudiced, then the purity of the verdict is open to serious doubt and the verdict should be set aside and a new trial awarded.””
4 later decisions quote this exact passage“Evidence is admissible if it is both relevant and material,”
2 later decisions quote this exact passage“The principle is well settled that a juror may not impeach a verdict solely upon his mental processes. Here, however, the alleged misconduct was not the jurors’ mental processes, but the evidence, aliunde, which may have influenced their mental processes. When there is a probability that such external evidence has influenced the jury, the court has “the affirmative duty ‘to investigate the charges and to ascertain whether . . . as a matter of fact, the jury was guilty of such misconduct.’ ” Accordingly, we hold that the affidavits proffered to the court and made a part of the record warranted further investigation by the court.”
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.