Commonwealth v. Meadius’s Empirical Analysis

Citation profile

35 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Rule 600, as noted, does not speak explicitly to the manner in which serial filing cases should be handled. While this Court has determined that the Commonwealth may not obtain the benefit of the second date where the re-filing is intended to evade the rule’s time limits, [...] it has never faced the distinct question of whether the same result should obtain where the serial filing is brought about because the prosecution does not exercise due diligence. We believe that it should. The rule’s focus upon allowing the prosecution time extensions only where it has acted diligently and where the delays in question were caused by factors beyond its control supports an interpretation whereby it must forego the benefit of a second filing date when these conditions are not met. Indeed, a contrary result would undermine the rule’s own facial requirements directed to prosecutorial diligence, as well its objectives, which include advancing society’s interests in seeing those accused of crime prosecuted in a timely manner, [... ] as well as ensuring the efficient management of criminal cases as a means of avoiding substantial backlogs[.]”

   2 later decisions quote this exact passage
   e.g. 2016 Pa. Super. 116 - Commonwealth v. Dixon · 2007 Pa. Super. 268 - Commonwealth v. Surovcik

2. “Rule 600. Prompt Trial (A) [...]. (3) Trial in a court case in which a written complaint is filed against the defendant, when the defendant is at liberty on bail, shall commence no later than 365 days from the date on which the complaint is filed. (G) For defendants on bail after the expiration of 365 days, at any time before trial, the defendant or the defendant’s attorney may apply to the court for an order dismissing the charges -with prejudice on the ground that this rule has been violated! • • • ]. If the court, upon hearing, shall determine that the Commonwealth exercised due diligence and that the circumstances occasioning the postponement were beyond the control of the Commonwealth, the motion to dismiss shall be denied and the case shall be listed for trial on a date certain. If, on any successive listing of the case, the Commonwealth is not prepared to proceed to trial on the date fixed, the court shall determine whether the Commonwealth exercised due diligence in attempting to be prepared to proceed to trial. If, at any time, it is determined that the Commonwealth did not exercise due diligence, the court shall dismiss the charges and discharge the defendant ... ].”

   1 later decision quote this exact passage
   e.g. 2007 Pa. Super. 268 - Commonwealth v. Surovcik

3. “Rule 600(A)(3) provides trial in a court case where a written complaint is filed against the defendant who is at liberty on bail must commence no later than 365 days from when the complaint is filed. Certain periods are excludable from computation of the period for commencement of trial, including delay resulting from the unavailability of the defendant or his attorney, or any continuance granted at the request of the defendant and his attorney. Pa.R.Crim.P. 600(C)(3)(a)-(b). If the court determines the Commonwealth exercised due diligence, and the circumstances occasioning the postponement were beyond the Commonwealth’s control, the motion to dismiss on speedy trial grounds shall be denied. Id., 600(G).”

   1 later decision quote this exact passage
   e.g. 2013 Pa. Super. 42 - Commonwealth v. Miskovitch