State v. Kay’s Empirical Analysis

Citation profile

3 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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “'scheme or artifice' compels the conclusion that communications fraud is a continuing offense inasmuch as 'schemes continue as long as they are in operation.' " Id. ¶ 18. We acknowledged that "[a]mple authority recognizes that an ongoing criminal design or scheme is not the same as a continuing offense[,]”

   1 later decision quote this exact passage · from the majority
   e.g. State v. Stewart

2. “criminal liability attaches when every element is satisfied, [but] the statute of limitations does not begin to run until the perpetrator ceases to satisfy the elements of the crime. At that point, the whole arc of criminal conduct is aggregated into a single criminal violation.”

   1 later decision quote this exact passage · from the majority
   e.g. State v. Stewart

3. “¶ 22 Kay examined the question of whether or not communications fraud is considered a continuing offense. Id. ¶ 9. We concluded that communications fraud is not a continuing offense, despite the State's argument that the language”

   1 later decision quote this exact passage · from the majority
   e.g. State v. Stewart