6 Va. App. 640 - Wolfe v. Commonwealth’s Empirical Analysis
1988
Citation profile
37 state decisions
How this case has been cited
Cited by 37 later decisions — most recently July 2014 · most notably 16 Va. App. 82 - Pugliese v. Commonwealth (1993), 12 Va. App. 512 - Lee v. Lee (1991)
37 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 North Carolina v. Pearce · Ashe v. Swenson · United States v. Powell · Dunn v. United States · Turner v. Murray
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘The most that can be said in such cases is that the verdict shows that either in the acquittal or the conviction the jury did not speak their real conclusions, but that does not show that they were not convinced of the defendant’s guilt. We interpret the acquittal as no more than their assumption of a power which they had no right to exercise, but to which they were disposed through lenity.’ ” ... [Jjuries may reach inconsistent verdicts through mistake, compromise, or lenity, but in such instances it is “unclear whose ox has been gored,” the government’s or the defendant’s. For this reason and the fact that the government is precluded from appealing the acquittal verdict, the Court concluded that inconsistent verdicts should not provide the basis for an appeal by the defendant.”
2 later decisions quote this exact passage“[t]he doctrine of collateral estoppel has not been held, and we believe properly so, to be applicable where two charges are tried in a single criminal jury trial. The statement of the doctrine itself contemplates a second trial in that an “issue cannot again be litigated between the same parties in any future law suit.””
1 later decision quote this exact passage“there are sound tactical reasons why an accused would not desire such an instruction and thus permit the jury to show leniency in convicting him of a lesser included offense of the primary felony; i.e., in this case voluntary manslaughter rather than murder.”
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.