State v. Marlowe’s Empirical Analysis

Citation profile

57 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 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[w]here multiple crimes are committed together during the course of one continuous crime spree, a defendant may be convicted once for possession of a firearm during the commission of a crime as to every individual victim of the crime spree, as provided under OCGA § 16-11-106 (b) (1), and additionally once for firearm possession for every crime enumerated in subsections (b) (2) through (5).”

   3 later decisions quote this exact passage
   e.g. Thomas v. State · Smith v. State

2. “In Pearson , the Court of Appeals permitted ten possession offenses simply because there were ten predicate felonies. A proper analysis permits three possession charges based on the crimes committed against three separate victims, and two possession charges based on the crimes of burglary and motor vehicle hijacking. The remaining possession charges, predicated on multiple felonies committed against the victims, should have been merged. *”

   1 later decision quote this exact passage
   e.g. Pearson v. State

3. “in Marlowe , the Court of Appeals properly merged the two possession offenses stemming from attempted robbery and aggravated assault against a single victim. However, the possession charge predicated on the burglary count, a crime involving illegal entry into a building, would stand.”

   1 later decision quote this exact passage
   e.g. 274 Ga. App. 535 - Marlowe v. State