State v. Norregaard’s Empirical Analysis

Citation profile

19 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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In deciding whether two or more intentional crimes were part of a single behavioral incident, one must focus on the factors of time and place and also consider whether the segments of conduct involved were motivated by a desire to obtain a single criminal objection. State v. Johnson, 273 Minn. 394, 404 , 141 N.W.2d 517, 525 (1966). One must also bear in mind that one of the main purposes of the statute is to protect a defendant convicted of multiple offenses against unfair exaggeration of the criminality of his conduct. See id. at 399-400 , 141 N.W.2d at 522 . Whether or not a robbery, on the one hand, and an assault or rape, on the other, were committed as part of a single behavioral incident depends on the facts of the case. Compare State v. Kutchara, 350 N.W.2d 924 (Minn.1984) (assault with a dangerous weapon and attempted robbery were part of same behavioral incident because assault was in furtherance of the robbery) with State v. McAdoo, 330 N.W.2d 104 (Minn.1983) (attempted robbery and assault with a dangerous weapon were not part of same behavioral incident because defendant fired gun at police after making decision to “get” them, not to facilitate commission of robbery or of escape from apprehension).”

   2 later decisions quote this exact passage
   e.g. State v. Hartfield · State v. Hill

2. “Section 609.035 prohibits multiple sentences, even concurrent sentences, for two or more offenses that were committed as part of a single behavioral incident.”

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