2012 Pa. Super. 150 - Commonwealth v. Brown’s Empirical Analysis

Citation profile

9 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Our Supreme Court has consistently recognized that admission of distinct crimes may be proper where it is part of the history or natural development of the case, i.e., the res gestae exception. [... 0]ur Supreme Court explained, the res gestae exception to the general proscription against evidence of other crimes, is also known as the complete story rationale, ie., evidence of other criminal acts is admissible to complete the story of the crime on trial by proving its immediate context of happenings near in time and place. Where the res gestae exception is applicable, the trial court must balance the probative value of such evidence against its prejudicial impact. In conducting this balancing test, courts must consider factors such as the strength of the other crimes evidence, the similarities between the crimes, the time lapse between crimes, the need for the other crimes evidence, the efficacy of alternative proof of the charged crime, and the degree to which the evidence probably will rouse the jury to overmastering hostility.”

   1 later decision quote this exact passage
   e.g. 2017 Pa. Super. 261 - Commonwealth v. Yocolano

2. “the history of the res gestae exception demonstrates that it is properly invoked when the bad acts are part of the same transaction involving the charged crime. We have found no case analogous to the one presented herein, nor has the Commonwealth cited to a single case where the sole exception to allowing the bad acts evidence was the res gestae /natural development exception and the evidence was not close in time and place from the acts charged.”

   1 later decision quote this exact passage
   e.g. 2013 Pa. Super. 249 - Commonwealth v. Green

3. “which are so clearly and inextricably mixed up with the history of the guilty act itself as to form part of one chain of relevant circumstances, and so could not be excluded on the presentation of the case before the jury without the evidence being rendered thereby unintelligible.”

   1 later decision quote this exact passage
   e.g. Commonwealth v. Knoble