Commonwealth v. Sullens’s Empirical Analysis
1992
Citation profile
3 federal appellate · 30 state decisions
How this case has been cited
Cited by 33 later decisions — most recently October 2013 · most notably Commonwealth v. Pursell (1999), United States v. Joseph (1995)
3 federal appellate · 30 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 Illinois v. Allen · Bethlehem Steel Corp. v. Pemberton · United States v. Houtchens · Commonwealth v. Africa · Commonwealth v. Klobuchir
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A contrary rule ... would be a travesty of justice. It would allow an accused at large upon bail to immobilize the commencement of a criminal trial and frustrate an already overtaxed judicial system until the trial date meets, if ever, with his pleasure and convenience. It would permit a defendant to play cat and mouse with the prosecution to delay the trial in an effort to discourage the appearance of prosecution witnesses. A defendant has a right to his day in court, but he does not have the right unilaterally to select the day and the hour.”
3 later decisions quote this exact passage · from the concurrence“(a) The defendant shall be present at the arraignment, at every stage of the trial including the impaneling of the jury and the return of the verdict, and at the imposition of sentence, except as otherwise provided by this rule. The defendant’s absence without cause shall not preclude proceeding with the trial including the return of the verdict.”
3 later decisions quote this exact passage · from the majority“The Superior Court [an intermediate appellate court] reasoned that to permit a defendant to halt the proceedings by absconding during trial would encourage him to avoid an expected verdict of guilt. It is equally apparent that apply ing a different rule when a defendant fails to appear at all, ... has precisely the same effect: it encourages a defendant to ignore his summons to trial if he thinks a guilty verdict is likely, secure in the knowledge that he cannot be convicted until he is apprehended. In the words of the late Mr. Justice McDermott: “No society on earth offers more than we do to preserve and protect the rights of those held for trial. It is more than simple discourtesy not to attend. It is an anarchical contempt of everything that so many have died to preserve.” ... We hold that when a defendant is absent without cause at the time his trial is scheduled to begin, he may be tried in absentia.”
1 later decision quote this exact passage · from the majoritye.g. Pinkney v. State
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.