State v. Fry’s Empirical Analysis
2005
Citation profile
32 state decisions
How this case has been cited
Cited by 33 later decisions — most recently May 2021 · most notably State v. Belton (Slip Opinion) (2016), Nunnery v. State (2011)
32 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 United States v. Booker · Apprendi v. New Jersey · Daubert v. Merrell Dow Pharmaceuticals, Inc. · Blakely v. Washington · In the Matter of Samuel Winship
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The defendant Thomas Vigil may be found guilty of felony murder as charged in Count 1, even though the defendant did not commit the murder if the state proves to your satisfaction beyond a reasonable doubt that: 1. The felony of shooting at a motor vehicle was committed; 2. The defendant Thomas Vigil helped, encouraged or caused the felony of shooting at a motor vehicle to be committed; 3. The defendant Thomas Vigil intended that the shooting at a motor vehicle be committed; 4. During the commission of the felony Carlos Escobar was killed; 5. The defendant Thomas Vigil helped, encouraged or caused the killing to be committed; 6. The defendant Thomas Vigil intended the killing to occur or knew that he was helping to create a strong probability of death or great bodily harm; 7. The defendant did not act in self defense; 8. This happened in New Mexico on or about the 21st day of October, 2005.”
1 later decision quote this exact passage · from the dissente.g. State v. Vigil“'to stick somebody tonight.' " Id. ¶ 2. Fry and his accomplice found the victim stranded at a Farmington convenience store, where she was crying at a payphone, and offered to drive her to her home in Shiprock. Id. ¶ 3. The victim left with Fry and his accomplice but tried to walk away when Fry stopped the car on a dirt road to relieve himself. Id. Fry convinced her to get back in the car and briefly drove on before he stopped and pulled the victim out of the car by her hair. Id. ¶¶ 3-4. He then attempted to disrobe the victim and, when she struggled, stabbed her in the chest. Id. ¶ 4. The victim pulled the knife out and tried to run away, but Fry caught her and hit her in the back of the head with a sledgehammer "at least three and possibly five times.”
1 later decision quote this exact passagee.g. Fry v. Lopez“Article IX of the Treaty, upon which [the djefendant relies and which protects the free exercise of religion ‘in the mean time,’ was designed only to address the interim period between the ratification of the Treaty and ‘the enjoyment of all the rights of citizens of the United States’ once individuals were admitted as citizens following the one year allowed in Article VIII, 9 Stat. 922 , for the election of citizenship.”
1 later decision quote this exact passage · from the concurrence
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.