State v. Castle’s Empirical Analysis
1997
Citation profile
54 state decisions
How this case has been cited
Cited by 57 later decisions (3 by the Supreme Court) — most recently December 2025 · most notably Lilly v. Virginia (1999), State v. Beavers (1999)
54 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 Blockburger v. United States · Keeble v. United States · Williamson v. United States · 35 Cal. 3d 510 - People v. Geiger · State v. Buckley
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.
“The purpose of this rule is to ensure reliability in the fact-finding process. It avoids the situation where the jury, convinced that the defendant is guilty of some crime, although not necessarily the crime charged, convicts the defendant rather than let his action go unpunished simply because the only alternative was acquittal.”
6 later decisions quote this exact passage · from the majority“(a) is established by proof of the same or less than all the facts required to establish the commission of the offense charged; (b) consists of an attempt to commit the offense charged or to commit an offense otherwise included in the offense charged; or (c) differs from the offense charged only in the respect that a less serious injury or risk to the same person, property, or public interest or a lesser kind of culpability suffices to establish its commission. [§46-1-202(9), MCA.]”
3 later decisions quote this exact passage · from the majority“'[a] lesser-included offense instruction is not supported by the evidence when the defendant's evidence or theory, if believed, would require an acquittal.' " Daniels , ¶ 12 (citing Jay , ¶ 42 ). However, when a defendant presents an alternative theory, supported by evidence, which would, if believed, require acquittal of a higher charge, but nonetheless permit conviction on a lesser-included offense, then he satisfies the Castle test and is entitled to a lesser-included offense instruction. Daniels , ¶ 15 . "It is a fundamental rule in this state that a criminal defendant is entitled to jury instructions that cover every issue or theory having support in the evidence.”
2 later decisions quote this exact passage · from the majority
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.