State v. Phillips’s Empirical Analysis

Citation profile

72 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 72 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “There are three factors examined in determining whether a direct causal connection is present: time, distance, and the causal relationship between the underlying felony and the killing. [Citations omitted.]”

   5 later decisions quote this exact passage · from the majority
   e.g. State v. Wilson · State v. Nesbitt

2. ““The res gestae element is satisfied because [the victim’s] murder occurred immediately after the happening of the principal occurrence—aggravated robbery—-and thus became so closely connected with the principal occurrence as to form a part of the occurrence. A direct causal connection is also present. The time element is met because there was evidence the events happened quickly and that [the defendant] moved from his aggravated robbery of [one individual] immediately to tire bedroom where [the female acquaintance] struggled with [the victim]. The distance factor is satisfied because tire aggravated robberies of [the individuals] occurred in the same house where [tire victim] was shot. Lastly, the causal relation is also satisfied because it is foreseeable that violence will erupt during an aggravated robbery in which the robber carries a gun. “The very nature of an aggravated robbery is violent. Moreover, [the defendant] stuck a potato on the end of his gun, indicating his preparation to silently shoot the gun. . . . [The defendant] set off a chain of violent events when he planned on robbing a house and brought a gun in furtherance of that plan. The elements of time, distance, and causal relationship were met. Accordingly, the evidence, when viewed in a light most favorable to the prosecution, was sufficient to establish beyond a reasonable doubt that the murder occurred during the res gestae of the aggravated robberies.” Phillips, 295 Kan. at 941-42 .”

   1 later decision quote this exact passage · from the majority
   e.g. State v. McClelland

3. “"In Count 9, the defendant is charged with interference with law enforcement by obstructing legal process. The defendant pleads not guilty. To establish this charge, each of the following claims must be proved: "1. Deputy Henry Cocking was authorized by law to execute an arrest warrant for the defendant. "2. The defendant knowingly opposed Deputy Cocking in the execution of that arrest warrant. "3. At the time the defendant knew or should have known that Deputy Cocking was authorized by law to execute the arrest warrant. "4. This act occurred on or about the 15th day of September, 2016, in Sedgwick County, Kansas. "The parties have stipulated and agreed that on or about September 15, 2016, there was a felony arrest warrant for the defendant in effect and outstanding. You should consider that fact as relates to this claimed offense as proven beyond a reasonable doubt."”

   1 later decision quote this exact passage · from the majority
   e.g. State v. Cox