Commonwealth v. Simmons’s Empirical Analysis
1975
Citation profile
85 state decisions
How this case has been cited
Cited by 85 later decisions — most recently June 2010 · most notably 84 Ill. 2d 415 - People v. Housby (1981), 263 Pa. Super. 206 - Commonwealth v. Madison (1979)
85 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 In the Matter of Samuel Winship · Leary v. United States · Turner v. United States · Eisenstadt v. Baker · Barnes 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 85 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"none of [the cases] holds that it is unconstitutional to infer from possession of stolen goods that the possessor knew they were stolen. Rather, the principle to be distilled from the several plurality and other opinions is that a conviction either based upon that inference alone, or reached without due regard to evidence of surrounding circumstances, cannot stand, because it is based on less than proof beyond a reasonable doubt. Such a conviction must be reversed, because proof beyond a reasonable doubt is a requirement of due process. Thus, the inference that the possessor of recently stolen goods knew they were stolen is not an `unconstitutional' inference (it is a common misstatement of Owens to say that it so held) (footnote omitted); rather it is an inference that, if misused, will in certain cases lead to an unconstitutional result." 233 Pa.Super. at 556-57, 336 A.2d at 629 .”
4 later decisions quote this exact passage · from the concurrence“[c]learly, evidence of possession of stolen property may be relevant in deciding whether the possessor is the one who stole it. However, as in a case of receiving stolen property, it is only one piece of evidence, and evidence of possession alone is not sufficient to prove burglary or larceny beyond a reasonable doubt.”
1 later decision quote this exact passage · from the concurrence“[b]ecause these crimes are by their definition inconsistent,. . . a judgment of sentence can only be imposed for one or the other. . . .”
1 later decision quote this exact passage · from the concurrence
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.