Commonwealth v. Simpson’s Empirical Analysis
1932
Citation profile
93 state decisions
How this case has been cited
Cited by 95 later decisions (2 by the Supreme Court) — most recently November 1999 · most notably Gori v. United States (1961), Commonwealth v. Baker (1964)
93 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 United States v. Sanges · Solomon Brantley v. State of Georgia · Commonwealth v. Wallace · Commonwealth v. Tenbroeck · Commonwealth v. Fitzpatrick
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 95 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“No person shall, for the same offense, be twice put in jeopardy of life or limb.”
2 later decisions quote this exact passage“It is true the Supreme Court of the United States has declared that by the use of the phrase `life or limb' in the Constitution of the United States, protection against double jeopardy is extended to all criminal offenses. It was so held in Ex Parte Lange, 18 Wallace 163. We have not followed this extreme view, but have permitted the retrial of offenses after juries have been discharged, although such an outcome could not be brought about under the federal interpretation. This ruling is not binding upon us, because the provision in the United States Constitution is a limitation upon the powers of the federal government and is not a limitation upon the states: Brantley v. Georgia, 217 U.S. 284 . The view which we are now taking, it may be admitted, was not that entertained by the court in Com. v. Fitzpatrick which followed Hilands v. Com. We think, however, our present construction comports more with sound public policy and with the necessity, now existing in dealing with law-breakers, for a reasonable interpretation of the criminal law. Hilands v. Com., 111 Pa. 1 , and Com. v. Fitzpatrick, 121 Pa. 109 , are overruled, so far as they are in conflict with this opinion.”
1 later decision quote this exact passage“The first question which confronts us is the right of the Commonwealth to appeal, defendant contending that it has no such right, citing in support of his position the authorities set forth in the note. The criminal law must move forward to meet the new conditions which confront organized society if its law-abiding members are to be protected in their personal and property rights. Whatever the rule may have been in past decades, we think now when there is such wide latitude allowed those convicted of crime to appeal and have their convictions reviewed, there should be a liberalizing of the attitude towards the Commonwealth, where the defendant has been convicted, and the question ruled against the Commonwealth, as here, is purely one of law. This is what we intended when we said in Com. v. Wallace, 114 Pa. 405, 411 [ 6 A. 685 ], ‘For error in quashing an indictment, arresting judgment after verdict of guilty, and the like, the Commonwealth may remove the record for review without special allowance of the proper writ.’”
1 later decision quote this exact passage
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.