State v. Lawrence’s Empirical Analysis

Citation profile

11 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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Lawrence claim [ed] that whether an out-of-state conviction constitutes a strike turns, not on the acts committed, but on the name assigned to the offending conduct by the foreign jurisdiction. The statute does not require such an absurd result. The statute lists certain substantive crimes and counts the convictions for those crimes whether committed in Washington or elsewhere. Whether an out-of-state conviction is equivalent to a crime listed in the statute requires a factual inquiry into the elements. Lawrence’s crime involves both threat and use of actual force, and a resulting injury. Thus, Lawrence’s prior conviction was for a crime with elements the same as those of a crime named in Washington’s statute. It is a strike under Washington law.”

   2 later decisions quote this exact passage
   e.g. 114 Wash. App. 800 - State v. Robinson · State v. Delgado

2. “(b)(i) Has been convicted of: (A) Rape in the first degree, rape of a child in the first degree, child molestation in the first degree, rape in the second degree, rape of a child in the second degree, or indecent liberties by forcible compulsion;.. . and (ii) Has, before the commission of the offense under (b)(i) of this subsection, been convicted as an offender on at least one occasion, whether in this state or elsewhere, of an offense listed in (b)(i) of this subsection.”

   2 later decisions quote this exact passage
   e.g. 109 Wash. App. 61 - State v. Delgado · State v. Delgado

3. “the statement was made while the declarant was still under the influence of the event to the extent that [the] statement could not be the result of fabrication, intervening actions, or the exercise of choice or judgment.”

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