6 Va. App. 118 - Godwin v. Commonwealth’s Empirical Analysis
1988
Citation profile
32 state decisions
How this case has been cited
Cited by 34 later decisions — most recently June 2019 · most notably Satcher v. Commonwealth (1992), 11 Va. App. 380 - Ferrell v. Commonwealth (1990)
32 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 Alexander v. Virginia · Kirkpatrick v. Commonwealth · 1 Va. App. 241 - Sutphin v. Commonwealth · Lewis v. Commonwealth · Essex v. Commonwealth
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.
“A “common plan” exists when the “relationship among offenses ... is dependent upon the existence of a plan that ties the offenses together and demonstrates that the objective of each offense was to contribute to the achievement of a goal not attainable by the commission of any of the individual offenses.” A conspiracy involving more than one offense is a typical example of offenses involving a common plan. Offenses using a “common plan,” however, should be “distinguished from similar character offenses (where the offenses merely duplicate each other).””
3 later decisions quote this exact passage“A trial court has limited discretion to order an accused to be tried for more than one offense at the same time. Rule 3A:10(b). The court may exercise this discretion only when justice does not “require separate trials” and (1) the Commonwealth’s attorney and the accused consent to the charges being tried together or (2) the offenses meet the requirements of Rule 3A:6(b). Rule 3A:10(b).”
3 later decisions quote this exact passage“the offenses are based on the same act or transaction, or on two or more acts or transactions that are connected or constitute parts of a common scheme or plan,”
2 later decisions 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.