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← 219 NW2D 3 - State v. Thomas

State v. Thomas’s Empirical Analysis

1974

Citation profile

36
cited by 36 later decisions
5
states following
December 2011
most recently cited

35 state decisions

How this case has been cited

Cited by 36 later decisions — most recently December 2011 · most notably Commonwealth v. Kostka (1976), Hinkle v. State (1980)

35 state decisions

20019741980199020002010decided

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 Cupp v. Naughten · Leland v. Oregon · Wardius v. Oregon · Cole v. United States · Davis v. United States

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

  1. “[I]f the defendant’s sanity is drawn in issue and substantial evidence appears in the record raising a fact question under the M’Naghten test — regardless of the source of that evidence — then the burden devolves upon the State to prove the defendant’s sanity beyond a reasonable doubt by all the evidence in the case including the presumption of sanity. As stated conversely in the Davis case regarding the jury’s duty, “If the whole evidence, including that supplied by the presumption of sanity, does not exclude beyond reasonable doubt the hypothesis of insanity, of which some proof is adduced, the accused is entitled to an acquittal of the specific offense charged.””
    2 later decisions quote this exact passage
  2. “[T]he State must not only establish the elements of the crime but, when the defendant's capacity to commit the crime at all is drawn into question and substantial evidence appears in the record raising a fact issue under the M'Naghten test, the State must also establish the defendant's sanity.”
    2 later decisions quote this exact passage
  3. ““ * * * We prefer to decide cases on nonconstitutional grounds when possible. City of Des Moines v. Lohner, 168 N.W.2d 779, 782 (Iowa) (‘We do not consider constitutional questions unless it is necessary for the disposition of the case.’); 16 Am.Jur.2d Constitutional Law § 113 at 301; 16 C.J.S. Constitutional Law § 94 at 317 (‘The principle that necessity of determination is a condition to judicial consideration of constitutional questions also finds application in the rule that such questions will not be passed on where the issues involved in the particular case may be decided on another ground, even though the constitutional issue has been properly presented.’) * * *.””
    1 later decision quote this exact passage

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.