Commonwealth v. Holder’s Empirical Analysis
2002
Citation profile
26 state decisions
How this case has been cited
Cited by 35 later decisions — most recently March 2023 · most notably Commonwealth v. Miller (2005), Commonwealth v. McNeal (2015)
26 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 Gagnon v. Scarpelli · Ashe v. Swenson · Benton v. Maryland · Black v. Romano · 51 Cal. 3d 335 - Lucido v. Superior Court
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“... The phrase “collateral estoppel,” also known as “issue preclusion,” simply means that when an issue of law, eviden-tiary fact, or ultimate fact has been determined by a valid and final judgment, that issue cannot be litigated again between the same parties in any future lawsuit. Collateral estoppel does not automatically bar a subsequent prosecution, but rather, it bars redetermination in a second prosecution of those issues necessarily determined between the parties in a first proceeding that has become a final judgment. Traditionally, Pennsylvania courts have applied the collateral estoppel doctrine only if the following threshold requirements are met: 1) the issues in the two actions are sufficiently similar and sufficiently material to justify invoking the doctrine; 2) the issue was actually litigated in the first action; and 3) a final judgment on the specific issue in question was issued in the first action. An issue is actually litigated when it is properly raised, submitted for determination, and then actually determined. For collateral estoppel purposes, a final judgment includes any prior adjudication of an issue in another action that is sufficiently firm to be accorded conclusive effect.”
2 later decisions quote this exact passage“On August 1, 1998, Mary Wright reported to Hatboro police that Appellant had raped her in her apartment. Appel lant was subsequently arrested and charged with [a variety of related ciimes.] ... In light of the fact that Appellant was on probation for a prior criminal conviction, he was sent to prison awaiting a probation revocation hearing, i.e., a Gagnon hearing. See Gagnon v. Scarpelli 411 U.S. 778 , 93 S.Ct. 1756 , 36 L.Ed.2d 656 [ ] (1973). During his Gagnon healing ..., Appellant tried to introduce evidence of a prior false rape allegation by Wright. Specifically, Appellant wanted to offer evidence that a week prior to this incident, after a night of drinking, Wright awoke in the middle of the night and asked [her friend] Michael Hunter, “Did you rape me last night?” Appellant intimated that he wanted to use Wright’s prior rape allegation to discredit her testimony that she trusted Appellant because he was Hunter’s friend, by showing that she actually did not even trust Hunter. The Gagnon hearing judge, Judge William Carpenter, ruled that this evidence was inadmissible, citing the rape shield law and hearsay rules. Judge Carpenter subsequently revoked Appellant’s probation. After Appellant’s trial for the rape and assault of Wright was scheduled, Appellant filed a pretrial motion ... to allow him to admit the same evidence that Judge Carpenter had previously excluded at the Gagnon hearing.... [T|he trial judge, Judge Paul Tressler, issued an order stating that Judge Carp”
1 later decision quote this exact passage“(a) written notice of the claimed violations of [probation or] parole; (b) disclosure to the [probationer or] parolee of evidence against him; (c) opportunity to be heard in person and to present witnesses and documentary evidence; (d) the right to confront and cross-examine adverse witnesses (unless the hearing officer specifically finds good cause for not allowing confrontation); (e) a “neutral and detached” hearing body such as a traditional parole board, members of which need not be judicial officers or lawyers; and (f) a written statement by the factfinders as to the evidence relied on and reasons for revoking [probation or] parole.”
1 later decision quote this exact passage · from the concurrence
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.