Commonwealth v. Dennis’s Empirical Analysis

Citation profile

7 federal appellate · 50 state decisions

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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “To warrant relief, after-discovered evidence must meet a four-prong test: (1) the evidence could not have been obtained before the conclusion of the trial by reasonable diligence; (2) the evidence is not merely corroborative or cumulative; (3) the evidence will not be used solely for purposes of impeachment; and (4) the evidence is of such a nature and character that a different outcome is likely.”

   2 later decisions quote this exact passage
   e.g. 2003 Pa. Super. 288 - Commonwealth v. Choice · In Re Lokuta

2. “In voir dire, the prosecutor exercised twenty peremptory challenges, dismissing thirteen African-American venirepersons, two Hispanic venirepersons, and five Caucasian venirepersons. [Dennis] argues that the prosecutor’s use of peremptory challenges violated [Batson] and that trial counsel was ineffective for failing to raise this issue. This argument is meritless. In the first instance, [Dennis] fails to indicate the race of forty-seven of the 170 venirepersons. Without such information, there is no basis for a [Batson] claim. See, e.g., Commonwealth v. Johnson, 542 Pa. 384 , 668 A.2d 97, 102 (1995), cert. denied, 519 U.S. 827 , 117 S.Ct. 90 , 136 L.Ed.2d 46 (1996) [(“[i]n order to establish prima facie case on Batson claim, defendant must make a record identifying the race of venirepersons stricken by the Commonwealth, the race of prospective jurors acceptable to the Commonwealth but stricken by the defense, and the racial composition of the final jury”)]. Furthermore, [Dennis] offers no evidence that the prosecutor exhibited racial animus in striking African-American venirepersons. Indeed, the impaneled jury included four African-American jurors and one African-American alternate, which indicates a lack of racial animus. Trial counsel was not ineffective for failing to raise a plainly baseless Batson claim.”

   1 later decision quote this exact passage
   e.g. Commonwealth v. Dennis

3. “Appellant argues that the case should be remanded to consider the statement of Shanaqua Ramsey, a friend of Zahra Howard, one of the eyewitnesses to the murder. On April 3, 1997, Ramsey gave an affidavit in which she stated that when Zahra Howard returned to school after the murder, she told Ramsey that she was not sure if the person she identified (Appellant) was the killer because she did not get a good look at the killer. Ramsey’s statement fails to meet at least two prongs of the after-discovered evidence test: the alleged conversation between Ramsey and Zahra Howard took place nearly a year before trial, and there is no evidence that it was discoverable only after trial; and the evidence would only be used to impeach Zahra Howard. Hence, this claim warrants no relief.”

   1 later decision quote this exact passage
   e.g. 2003 Pa. Super. 288 - Commonwealth v. Choice