Commonwealth v. Creamer’s Empirical Analysis

Citation profile

41 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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “It is well-established law in the Commonwealth that before a county assumes jurisdiction over a crime, some overt act must have occurred therein. Commonwealth v. Tumolo, 223 Pa.Super. 189 , 299 A.2d 15 (1972), aff'd, 455 Pa. 424 , 317 A.2d 295 (1974); Commonwealth v. Simeone, 222 Pa.Super. 376 , 294 A.2d 921 (1972). Where a conspiracy is alleged, an overt act committed in a county by any one of the conspirators is sufficient for that county to assert jurisdiction over all. Commonwealth v. Thomas, 410 Pa. 160 , 189 A.2d 255 (1963); Commonwealth v. Simeone, supra . "The case law of the Commonwealth is replete with examples of a county's assertion of jurisdiction when some part of the criminal activity or conspiracy occurred therein. See, e. g., Commonwealth v. Thomas, supra ; Commonwealth v. Tumolo, supra ; Commonwealth v. Marino, 213 Pa.Super. 88 , 245 A.2d 868 (1968), aff'd, 435 Pa. 245 , 255 A.2d 911 (1969), cert. denied, 397 U.S. 1077 , [ 90 S.Ct. 1526 , 25 L.Ed.2d 811 ,] reh. denied, 398 U.S. 945 [, 90 S.Ct. 1849 , 26 L.Ed.2d 284 ] (1970); Commonwealth v. Petrosky, 194 Pa.Super. 94 , 166 A.2d 682 (1960); Commonwealth v. Prep, 186 Pa.Super. 442 , 142 A.2d 460 (1958); Commonwealth v. Mezick, 147 Pa.Super. 410 , 24 A.2d 762 (1942).”

   1 later decision quote this exact passage
   e.g. 275 Pa. Super. 304 - Commonwealth v. Brinton

2. ““Status as a public officer is not normally at issue when the obstruction of justice is alleged. If it is to be made an issue, it should be alleged in the indictment. Therefore, Mr. Creamer should have been informed in the indictment that he would be required to defend against the crimes of conspiracy and obstruction of justice, and against the six-year statute of hmitations. Because the issue of his status as a pubhc officer is relevant ,not only to the extended hmitations period but to possible defenses which may be asserted by a pubhc official who acts in the performance of his duties, appellant should have been indicted for acts committed by him in his capacity as Attorney General.” (Emphasis in original.)”

   1 later decision quote this exact passage
   e.g. Commonwealth v. Capozello

3. ““It is well-established law in the Commonwealth that before a county assumes jurisdiction over a crime, some overt act must have occurred therein (Citations omitted). Where a conspiracy is alleged, an overt act committed in a county by any one of the conspirators is sufficient for that county to assert jurisdiction over all.” (Citations omitted)”

   1 later decision quote this exact passage
   e.g. Commonwealth v. Keenan