6 Va. App. 598 - Grogg v. Commonwealth’s Empirical Analysis
1988
Citation profile
3 federal appellate · 45 state decisions
How this case has been cited
Cited by 48 later decisions — most recently April 2014 · most notably 20 Va. App. 373 - Novak v. Commonwealth (1995), 19 Va. App. 295 - Browning v. Commonwealth (1994)
3 federal appellate · 45 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 Miranda v. State of Arizona Vignera · Schneckloth v. Bustamonte · United States v. Wade · Edwards v. Arizona · Gault
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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The test to be applied in determining voluntariness [of waiver] is whether the statement is the ‘product of an essentially free and unconstrained choice by its maker,’ or ... whether the maker’s will ‘has been overborne and his capacity for self-determination critically impaired.’ ” Stockton v. Commonwealth, 227 Va. 124, 140 , 314 S.E.2d 371, 381 (1984) (quoting Schneckloth v. Bustamonte, 412 U.S. 218, 225 , 93 S.Ct. 2041, 2046 , 36 L.Ed.2d 854 (1973)). The Commonwealth, however, must prove not only that the waiver was voluntary, but also knowing and intelligent. Edwards [v. Arizona, 451 U.S. 477, 483-84 , 101 S.Ct. 1880, 1883-84 , 68 L.Ed.2d 378 (1981)]. * * * # * * In deciding the question whether an accused has knowingly and intelligently waived these rights established in Miranda , and thus whether statements made by an accused during custodial interrogation are admissible against him, an inquiry into the totality of the circumstances surrounding the interrogation must be made. Fare [v. Michael C., 442 U.S. 707, 725 , 99 S.Ct. 2560, 2571-72 , 61 L.Ed.2d 197 (1979)] (citing Miranda, 384 U.S. at 475-77 , 86 S.Ct. 1602 ). The Supreme Court held in Fare that the totality of circumstances approach is appropriate where the issue is whether a juvenile has made a valid waiver. 442 U.S. at 725 , 99 S.Ct. 2560 . Our Supreme Court adopted this approach in Harris v. Commonwealth, 217 Va. 715, 719-20 , 232 S.E.2d 751, 754-55 (1977), and Green v. Commonwealth, 223 Va. 706, 710 , 292 S”
3 later decisions quote this exact passage“it is desirable to have a parent, counsel or some other interested adult or guardian present when the police interrogate a juvenile, and it is even more desirable to have an interested adult present when a juvenile waives fundamental constitutional rights and confesses to a serious crime. However, it is well established that the mere absence of a parent or counsel does not render a waiver invalid.”
3 later decisions quote this exact passage“Code § 16.1-296 provides in pertinent part: “From any final order or judgment of the juvenile court affecting the rights or interests of any person coming within its jurisdiction, an appeal may be taken in accordance with the provisions of Chapter 7 (§ 16.1-123.1 et seq.) of Title 16.1.” Code § 16.1-136 provides in pertinent part: “Any appeal taken under the provisions of this Chapter [Chapter 7] shall be heard de novo in the appellate court . . . .””
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.