2014 Pa. Super. 148 - Commonwealth v. Jenkins’s Empirical Analysis
2014
Citation profile
9
cited by 9 later decisions
1
states following
May 2024
most recently cited
9 state decisions
Relationships
Relies on Blockburger v. United States · Commonwealth Ex Rel. Moszczynski v. Ashe · Commonwealth v. Anderson · Commonwealth v. Weakland · Commonwealth v. Comer
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.
“When considering whether there is a single criminal act or multiple criminal acts, the question is not “whether there was a ‘break in the chain’ of criminal activity.” The issue is whether “the actor commits multiple criminal acts beyond that which is necessary to establish the bare elements of the additional crime, then the actor will be guilty of multiple crimes which do not merge for sentencing purposes.””
2 later decisions quote this exact passage · from the dissent““Had the Commonwealth listed only the assaultive conduct that formed the basis of the simple assault charge against Jenkins at the robbery charge, we would conclude that Jenkins did not commit “multiple criminal acts beyond that which is necessary to establish the bare elements of the additional crime. *** However, the Commonwealth’s description of the conduct forming the basis of the robbery charge against Jenkins also included the Defendants’ conduct in restraining Caracillo on the ground. Cara-cillo’s testimony indicates that the Defendants restrained him by holding a foot to his head in a manner that exacerbated his existent facial injuries. N.T. at 100. This additional physical restraint caused Caracillo substantial pain. Id. These events would establish the “bodily injury’ element of robbery, even in the absence of the facts that established Jenkins’ conviction for simple assault.”
1 later decision quote this exact passage · from the dissent
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.