Commonwealth v. McMullen’s Empirical Analysis
1996
Citation profile
2 federal appellate · 31 state decisions
How this case has been cited
Cited by 34 later decisions — most recently August 2021 · most notably Commonwealth v. Fears (2003), Commonwealth v. Bardo (1998)
2 federal appellate · 31 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 In re the Primary Election of May 21, 1991 · Commonwealth v. Ware · Commonwealth v. Turza · Commonwealth v. Edwards · Commonwealth v. Byrd
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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the present matter, we have no difficulty concluding that the evidence independent of [Appellant’s] statement was insufficient to establish the corpus delicti for the homicide charge. The only evidence pointing to foul play were the bruises and lacerations on the decedent’s face, and the pathologist could not conclude that these blows were more likely caused by an assailant than they were by decedent’s striking objects after falling into the water. On the other hand, much evidence pointed to the decedent’s death being an accident, including the lack of signs of a struggle and decedent’s own behavior.”
3 later decisions quote this exact passage“In the late evening or early morning hours of February 23-24, 1985, the Grocery Box, a food store in Orbisonia, Pennsylvania, was burglarized. Eight days later, on March 4,1985, the body of Dominic Barcelona was recovered from Black Log Creek, not far from the Grocery Box. The body was about 400 to 500 yards downstream from a highway bridge and about 300 yards downstream from a railroad bridge. Barcelona, a 80-year old schizophrenic, was well known throughout the community for his habit of taking extensive walks. He also walked with a limp sustained as a result of being hit by a car during one of these walks. At the time of these events, the police made no connection between the burglary and Barcelona’s death. Instead, police concluded that Barcelona accidentally drowned because neither Barcelona’s body nor the location of his death bore evidence of foul play. This conclusion was supported by the pathologist who autopsied Barcelona and also by the county coroner. However, after rumors surfaced that the burglary and drowning were related, the Pennsylvania State Police reopened both investigations in the latter part of 1989. [Appellant], who was then incarcerated on other charges, gave a statement averring that he and another man, Adam Wiser, burglarized the Grocery Box and, while fleeing, encountered Barcelona on a nearby bridge. McMullen, 420 Pa.Super. at 133, 616 A.2d at 15. [Appellant] further stated that Wiser, not he, threw Barcelona into the creek after apparently knocki”
1 later decision quote this exact passage“Before introducing an extra-judicial admission, the Commonwealth must establish by independent evidence that a crime has in fact been committed; however, the Commonwealth is not required to prove the existence of a crime beyond a reasonable doubt.... The corpus delicti, like other facts, may be shown by circumstantial evidence; it is sufficient if these circumstances are consistent with a crime even though they are also consistent with ... an accident. However, it is insufficient if it is merely as consistent with an accident as with a crime.”
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.