Evans v. State’s Empirical Analysis

Citation profile

37 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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The “substantial step” language of OCGA § 16-4-1 shifts the emphasis from what remains to be done to what the actor has already done. The fact that further steps must be taken before the crime can be completed does not preclude such a finding that the steps already undertaken are substantial. In addition to assuring firmness of criminal purpose, the requirement of a substantial step will remove very remote preparatory acts from the ambit of attempt liability and the relatively stringent sanctions imposed for attempts.”

   2 later decisions quote this exact passage
   e.g. 312 Ga. App. 489 - Brown v. State · Rainey v. the State

2. “[The appellants’] discussion regarding the theft of a car stereo and their possession of tools to aid in the commission of such a theft, without more, would not have amounted to an attempt to enter an automobile, but merely would have been preparatory acts not proximately leading to the consummation of the crime of entering an automobile. [The appellants], however, went beyond these remote acts of preparation when they drove to the shopping center parking lots in search of a specific car to enter.”

   1 later decision quote this exact passage
   e.g. Rainey v. the State