People v. Miles’s Empirical Analysis
1969
Citation profile
16 federal appellate · 55 state decisions
How this case has been cited
Cited by 83 later decisions — most recently July 2021 · most notably State v. Logan (1979), Government of Virgin Islands v. Berry (1979)
16 federal appellate · 55 state decisions — followed in 14 states
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 Chapman v. State of California · Escobedo v. Illinois · Walder 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 83 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In short, the Levy * * * rule was designed to prevent gross distortion of lesser crimes into a much more serious crime by excess of prosecutorial zeal. It was not designed to merge “true" kidnappings into other crimes merely because the kidnappings were used to accomplish ultimate crimes of lesser or equal or greater gravity. Moreover, it is the rare kidnapping that is an end in itself; almost invariably there is another ultimate crime. [Emphasis added]”
3 later decisions quote this exact passagee.g. State v. Masino · State v. Stouffer““***The more complicated nature of the asportation, with changes in purpose and direction, first to a place in New Jersey, and then to New York, for purposes connected with but not directly instrumental to the attempt to kill Brooks, removes this case from the exception of the Levy-Lombardi rule. u * * * “***Nor was the Levy-Lombardi rule intended to exclude from the ‘traditional’ or ‘conventional’ kidnapping abductions designed to effect extortions or accomplish murder.””
1 later decision quote this exact passagee.g. State v. Logan“1.The movement element must not be “merely incidental” to the commission of another underlying lesser crime. 2. The movement of a “more complicated nature” may sustain a kidnapping charge. 3. Statutory kidnapping continues to include “traditional” or “conventional” kidnapping abductions designed to effect extortions or accomplish murder.”
1 later decision quote this exact passagee.g. Salter v. State
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.