Lyons v. State’s Empirical Analysis
1989
Citation profile
16 state decisions
How this case has been cited
Cited by 16 later decisions — most recently February 2018
16 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. Alford · United States v. Harriss · Maynard v. Cartwright · Winters v. People of State of New York · Bryant v. State
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As used in this chapter: 1. “Cheat” means to alter the elements of chance, method of selection or criteria which determine: (a) The result of a game; (b) The amount or frequency of payment in a game; or (c) The value of a wagering instrument approved by the state gaming control board for use in connection with a cashless wagering system. 2. The words and terms defined in chapter 463 of NRS have the meanings ascribed to them in that chapter.”
2 later decisions quote this exact passagee.g. Childs v. State · Skipper v. State“Moreover, we also observed that “the attributes of the game — its established physical characteristics and basic rules — determine the probabilities of the game’s various possible outcomes. Changing those attributes to affect those probabilities is a criminal act.” [ 99 Nev. at 341 ]; 662 P.2d at 638 . Games in the form of slot machines have established physical characteristics that are not altered by handle popping. Furthermore, we are unaware of any rules, written or otherwise, directing slot machine patrons to pull the handles in a specific manner. Certain gaming sophisticates — such as Lyons — would undoubtedly manipulate handles with a form of scienter because of their awareness that the procedure forms a basis for criminal prosecution in Nevada. Others . . . who stumble across a more favorable method of play, will handle pop without an intent to cheat or defraud. It is clear however, that crime categories do not materialize or disappear on an ad hoc basis because of the presence or absence of scienter. Public offenses are defined by statute, ordinance or the common law. See NRS 193.050.”
1 later decision quote this exact passage · from the dissente.g. Childs v. State“In light of the statutory purpose, we interpret the current cheating statutes to proscribe the alteration of the group of characteristics which identify and define the game in question. The attributes of the game — its established physical characteristics and basic rules — determine the probabilities of the game’s various possible outcomes. Changing those attributes to affect those probabilities is a criminal act. Thus, if a player or dealer deceitfully alters the identifying characteristics or attributes of a game with the intent to deprive another of money or property by affecting the otherwise established probabilities of the game’s various outcomes, he or she is guilty of cheating within the meaning of NRS 465.015 and NRS 465.083.”
1 later decision quote this exact passage · from the dissente.g. Skipper v. State
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.