349 Pa. Super. 335 - Commonwealth v. Drexel’s Empirical Analysis
1986
Citation profile
10 state decisions
How this case has been cited
Cited by 10 later decisions — most recently January 2020
10 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 Commonwealth v. Ware · Commonwealth v. Turza · Commonwealth v. Milliken · Commonwealth v. Woodward · Commonwealth v. Byrd
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As I told you, you may not consider this statement as evidence against the defendant unless you first find beyond a reasonable doubt that a crime was committed. In making this preliminary determination, you may consider any direct or circumstantial evidence, apart from the aforesaid statement tending to prove or disprove a crime. More precisely, you must disregard the statement unless you are satisfied beyond a reasonable doubt by other evidence in the case than [sic] Dr. Paul Fried is dead, and that his death was probably caused by someone feloniously killing him. A killing is felonious if it is either murder or voluntary manslaughter by some person’s criminal act in suffocating him. The other evidence in this case, aside from the defendant’s aforesaid statement, need not tend to show that the crime was committed by the defendant, only that the crime was committed by someone. The other evidence need not rule out all possibility of accident, suicide or natural causes. It is enough if you are satisfied beyond a reasonable doubt that the cir cumstances are more consistent with death having been caused by a felonious killing by suffocation than in some other way. The object of these rales is to guard against convicting a person of a crime that never really happened even though the person confessed to it. (emphasis added).”
1 later decision quote this exact passage“It is clear, therefore, that the trial court erred when it instructed the jury that it had to “disregard [appellant's admission] unless [it was] satisfied by the other evidence that Thomas Morgan is dead and that his death was probably caused feloniously by someone killing him.” By this instruction the court permitted the jury — in theory, at least; whether in fact will be discussed next — to decide that a crime was committed only as a matter of probability, and then to proceed from that decision to the further decision that if a crime was committed, appellant was beyond a reasonable doubt the one who had committed it. This reasoning represents an impermissible dilution, or lessening, of the Commonwealth’s ultimate burden, and to avoid that, the court should have instructed the jury that before it could consider appellant’s admission, it had to be satisfied not probably but beyond a reasonable doubt that Morgan’s death was caused feloniously.”
1 later decision quote this exact passage“Pennsylvania has developed a corpus delicti rule of evidence that states that before the Commonwealth may introduce a defendant’s confession or admission, it must offer independent evidence that a crime in fact occurred. Commonwealth v. Moore, 466 Pa. 510, 513 , 353 A.2d 808, 809 (1976); Commonwealth v. Smallwood, 497 Pa. 476, 483 , 442 A.2d 222, 225 (1982); Commonwealth v. Byrd, 490 Pa. 544, 556 , 417 A.2d 173, 179 (1980); Commonwealth v. Palmer, 448 Pa. 282, 285-86 , 292 A.2d 921, 922 (1972). Such independent evidence need not conclusively prove that a crime was committed; rather, the rule is satisfied if the evidence “points to an unlawful killing, although it may indicate as well accident or suicide.” Commonwealth v. Coontz, 288 Pa. 74, 79 , 135 A. 538, 539 (1927). See also Commonwealth v. Byrd, supra, 490 Pa.”
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.