Palmer v. Commonwealth

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• recognizing that “concealment” is “admissible as evidence of consciousness of guilt” (quoting Langhorne v. Commonwealth, 13 Va. App. 97, 102 (1991))
• upholding the admission of evidence of the defendant’s refusal to comply with a court order directing him to shave and cut his hair in order to facilitate possible eyewitness identification because the refusal “suggest[ed] an attempt at concealment”
• an accused’s attempts to conceal the evidence of her crime are “admissible as evidence of consciousness of guilt, and thus of guilt itself”
• “[R]efusal to comply with the court order was a circumstance tending to show guilt and was properly considered by the trier of fact.”
• “[I]t is today universally conceded that the fact of an accused’s flight . . . and related conduct are admissible as evidence of consciousness of guilt, and thus of guilt itself.”
• “[I]t is today universally conceded that the fact of an accused’s flight, . . . concealment, . . . and related conduct are admissible as evidence of consciousness of guilt, and thus of guilt itself.” (emphasis added

Source: CourtListener parenthetical corpus (CC0).

Cited by

4 cases in this archive cite this case.

• Jeffrey Scott Haas v. Commonwealth of Virginia
  Court of Appeals of Virginia· 2019-10-29
• Adrian Donnel Aley v. Commonwealth of Virginia
  Court of Appeals of Virginia· 2022-06-14
• Zakeyis Ave'on Womack, s/k/a Zakeyis Aveon Womack v. Commonwealth of Virginia
  Court of Appeals of Virginia· 2024-10-08
• Jaeyoung Lee v. Commonwealth of Virginia
  Court of Appeals of Virginia· 2026-01-13

Cites

5 cases in this archive are cited by this case.

• United States v. O'Brien
  Supreme Court· 1968-05-27· cited 3,604×
• Stamper v. Commonwealth
  Supreme Court of Virginia· 1979-08-30· cited 380×
• Langhorne v. Commonwealth
  Court of Appeals of Virginia· 1991-09-17· cited 93×
• Gardner v. Commonwealth
  Court of Appeals of Virginia· 1986-11-05· cited 81×
• Norman v. Commonwealth
  Court of Appeals of Virginia· 1986-07-15· cited 69×