Commonwealth v. Evans’s Empirical Analysis
1986
Citation profile
2 federal appellate · 116 state decisions
How this case has been cited
Cited by 122 later decisions — most recently April 2023 · most notably Commonwealth v. Kimball (1999), Commonwealth v. Abu-Jamal (1998)
2 federal appellate · 116 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 Delaware v. Van Arsdall · Davis v. Alaska · Commonwealth v. Story · Commonwealth v. Slaughter · Commonwealth v. Cheatham
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 122 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“whenever a prosecution witness may be biased in favor of the prosecution because of outstanding criminal charges or because of any non-final criminal disposition against him within the same jurisdiction, that possible bias, in fairness, must be made known to the jury. Even if the prosecutor has made no promises, either on the present case or on other pending criminal matters, the witness may hope for favorable treatment from the prosecutor if the witness presently testifies in a way that is helpful to the prosecution. And if that possibility exists, the jury should know about it.”
26 later decisions quote this exact passage · from the majority“Art. I. Section 9 of the Pennsylvania Constitution, in pertinent part provides: In all criminal prosecutions the accused hath a right to be heard by himself and his counsel, to demand the nature and cause of the accusation against him, to meet the witnesses face to face____ The Sixth Amendment to the United States Constitution, in pertinent part provides: In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed ... and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him____”
2 later decisions quote this exact passage · from the majority“The jury may choose to believe the witness even after it learns of actual promises of leniency which may be made in the future, but the defendant, under the right guaranteed in the Pennsylvania Constitution to confront witnesses against him, must have the opportunity at least to raise a doubt in the mind of the jury as to whether the prosecution witness is biased. It is not for the court to determine whether the cross-examination for bias would affect the jury’s determination of the case____ While we have always acknowledged the right of a party to impeach by showing bias, new in the present case is our willingness to acknowledge what we had previously thought was too speculative: that a prosecution witness may be biased because of the expectation of leniency in some pending matter even when no promises have been made. Thus, we hold that the right guaranteed by Article I. Section 9 of the Pennsylvania Constitution to confront witnesses against a defendant must be permitted to challenge a witness’s self-interest by questioning him about possible or actual favored treatment by the prosecuting authority in the case at bar, or in any other non-final matter involving the same prosecuting authority-”
1 later decision 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.