State v. Lancaster’s Empirical Analysis
1993
Citation profile
162 state decisions
How this case has been cited
Cited by 162 later decisions — most recently August 2024 · most notably State v. Bell (1994), Insurance Commissioner v. Equitable Life Assurance Society of the United States (1995)
162 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 · Brown v. Ohio · Missouri v. Hunter · United States v. Dixon · Whalen v. United States
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 162 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The required evidence is that which is minimally necessary to secure a conviction for each statutory offense. If each offense requires proof of a fact which the other does not, or in other words, if each offense contains an element which the other does not, the offenses are not the same for double jeopardy purposes even though arising from the same conduct or episode. But, where only one offense requires proof of an additional fact, so that all elements of one offense are present in the other, the offenses are deemed to be the same for double jeopardy purposes.”
20 later decisions quote this exact passage“`case can be properly disposed of on a non-constitutional ground,'”
3 later decisions quote this exact passage“Another standard for determining merger ... has become known as the “rule of lenity.” ... [T]he rule provides that doubt or ambiguity ... “ ‘will be resolved against turning a single transaction into multiple offenses.’ ” The Supreme Court has applied the rule of lenity where the same act constitutes an offense under two different statutory provisions.... A few cases have attempted to formulate fixed criteria for deciding whether to apply the rule of lenity, and have indicated that unless two offenses merge under either the required evidence test or under these fixed criteria, there can be no merger. In our view, however, there should not be any rigid or fixed criteria for applying the rule of lenity.... ... The fairness of multiple punishments in a particular statute is obviously important. Consequently, despite the possible implication to the contrary in some prior Maryland cases, we do not believe that there is any rigid framework for determining whether the rule of lenity is applicable or that the rule of lenity is the exclusive principle for determining whether offenses, separate under the required evidence test, should merge.”
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.