Commonwealth v. Simeone’s Empirical Analysis
1972
Citation profile
42 state decisions
How this case has been cited
Cited by 42 later decisions — most recently September 2000 · most notably 51 Ohio App. 2d 31 - State v. Nelson (1977), 263 Pa. Super. 452 - Commonwealth v. Frank (1979)
42 state decisions
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 Benton v. Maryland · Commonwealth v. Mills · Commonwealth Ex Rel. Chatary v. Nailon · Commonwealth v. Farrell · Harrison v. Commonwealth
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is clear that where a defendant is tried for an offense by a court of competent jurisdiction, a second trial for the same offense would be a violation of the fifth amendment guarantee against double jeopardy, which has recently been held applicable to the states through the Fourteenth Amendment. Benton v. Maryland, 395 U.S. 784 , 89 S.Ct. 2056 , 23 L.Ed.2d 707 (1969). The questions then before this Court are (1) whether appellant was tried twice for the same offense, and (2) if so, whether he was tried by a court of competent jurisdiction in the first trial. “Offenses are not the same ‘for purposes of the double jeopardy’ clause of the 5th Amendment unless the evidence required to support conviction on one of the indictments would have been sufficient to warrant conviction on the other.” . . . Jurisdiction in Pennsylvania, however, is only countywide, . . . Therefore, the evidence that would have sustained a conviction in Philadelphia County would not have been sufficient to prove that appellant had received stolen goods in Bucks County. The offenses for which appellant was tried in Bucks County are entirely separate and distinct from the offenses for which appellant was tried in Philadelphia.”
1 later decision quote this exact passage · from the majority“The historic foundation for the rule [that subject matter jurisdiction of criminal courts extends only to offenses committed within the county of trial] is that “by the ancient law, 'all offenses were said to be done against the peace of the county; contra pacem vice comitis,' 1 Black. 117””
1 later decision quote this exact passage · from the majority
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.