State v. Washington’s Empirical Analysis

Citation profile

184 state decisions

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 184 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “We hold that when deciding whether to merge multiple offenses at sentencing pursuant to R.C. 2941.25, a court must review the entire record, including arguments and information presented at the sentencing hearing, to determine whether the offenses were committed separately or with a separate animus.”

   5 later decisions quote this exact passage · from the concurrence
   e.g. State v. Johnson · State v. Chidester

2. “(A) Where the same conduct by defendant can be construed to constitute two or more allied offenses of similar import, the indictment or information may contain counts for all such offenses, but the defendant may be convicted of only one. (B) Where the defendant’s conduct constitutes two or more offenses of dissimilar import, or where his conduct results in two or more offenses of the same or similar kind committed separately or with a separate animus as to each, the indictment or information may contain counts for all such offenses, and the defendant may be convicted of all of them.”

   3 later decisions quote this exact passage · from the concurrence
   e.g. State v. Earley (Slip Opinion) · State v. Lee

3. “'The defendant bears the burden of establishing his entitlement to the protection, provided by R.C. 2941.25, against multiple punishments for a single criminal act.'”

   3 later decisions quote this exact passage · from the concurrence
   e.g. State v. Zeigler · State v. Harmon