State v. Beach’s Empirical Analysis
1973
Citation profile
83
cited by 83 later decisions
1
states following
April 2014
most recently cited
81 state decisions
How this case has been cited
Cited by 83 later decisions — most recently April 2014 · most notably State v. Monk (1976), State v. Reid (1994)
81 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 State v. Stephens · State v. Benton · State v. Greer · State v. Riera · State v. Price
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.
“"One who advises, counsels, procures, encourages or assists another in the commission of a crime is an aider and abettor. (Citations omitted.) `A person aids and abets when he has "that kind of connection with the commission of a crime which, at common law, rendered the person guilty as a principal in the second degree. It consisted in being present at the time and place, and in doing some act to render aid to the actual perpetrator of the crime, though without taking a direct share in its commission."' (Citations omitted.)" State v. Beach, 283 N.C. 261, 266-267 , 196 S.E.2d 214, 218 (1973). ". . . One who procures or commands another to commit a felony, accompanies the actual perpetrator to the vicinity of the offense and, with the knowledge of the actual perpetrator, remains in that vicinity for the purpose of aiding and abetting in the offense and sufficiently close to the scene of the offense to render aid in its commission, if needed, or to provide a means by which the actual perpetrator may get away from the scene upon the completion of the offense, is a principal in the second degree and equally liable with the actual perpetrator. . . ." State v. Price, 280 N.C. 154, 158 , 184 S.E.2d 866, 869 (1971), and cases cited therein. ". . . While mere presence cannot constitute aiding and abetting in legal contemplation, a bystander does become a principal in the second degree by his presence at the time and place of a crime where he is present to the knowledge of the actual pe”
2 later decisions quote this exact passage““ ‘A person aids when, being present at the time and place, he does some act to render aid to the actual perpetrator of the crime though he takes no direct share in its commission; and an abettor is one who gives aid and comfort, or either commands, advises, instigates or encourages another to commit a crime.’ State v. Holland, 234 N.C. 354, 358 , 67 S.E. 2d 272 ; State v. Johnson, 220 N.C. 773, 776 , 18 S.E. 2d 358 . ‘ . . . Mere presence, even with the intention of assisting in the commission of a crime cannot be said to have incited, encouraged or aided the perpetration thereof, unless the intention to assist was in some way communicated to him (the perpetrator) . ... ’ State v. Hoffman, 199 N.C. 328, 333 , 154 S.E. 314 . However, there is an exception. ‘. . . when the bystander is a friend of the perpetrator, and knows that his presence will be regarded by the perpetrator as an encouragement and protection, presence alone may be regarded as an encouragement, and in contemplation of law this was aiding and abetting.’ State v. Holland, supra.” State v. Hargett, 255 N.C. 412, 415 , 121 S.E. 2d 589, 592 (1961).”
2 later decisions quote this exact passage“[I]f the jury did believe that [the defendants] Adams and Reid were acting in concert, then it could have also convicted Reid of the murder of Wilkes. The jury’s decision to acquit Reid on this crime may have been a demonstration of compromise or lenity for Reid. A case such as this, where the evidence, even among the witnesses for each side, is contradictory and confusing, is a prime example of why we should not attempt to enter the jury’s thought process to determine whether the jurors spoke their real conclusions in their conviction of Reid for assault, acquittal of Reid for murder, conviction of Adams for murder, or acquittal of Adams for assault. What we have done to protect defendant Reid froin an irrational jury is determine if the evidence was sufficient to find defendant guilty of assault with a deadly weapon with intent to kill inflicting serious injury beyond a reasonable doubt. We have concluded that viewing the evidence in the light most favorable to the State, the jury could have determined that defendant Reid was acting in concert with defendant Adams and found him guilty under this theory. Reid’s conviction will not be reversed on the ground that there were inconsistent verdicts in his trial.”
1 later decision quote this exact passagee.g. State v. Mumford
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.