State v. Watson’s Empirical Analysis

Citation profile

7 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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The State of Missouri ... alleges that on or about September 8, 2009 through September 9, 2009, defendant committed the act of involuntary manslaughter in the first degree, to wit: defendant recklessly caused the death of [Victim] by striking his head, or striking his head against an object, or by shaking him , in Instruction No. 5. To convict defendant of involuntary manslaughter in the first degree, one particular mechanism, listed in Instruction No. 5, first paragraph, of recklessly causing [Victim's] death must be proved beyond a reasonable doubt, and you must unanimously agree as to which mechanism has been proven. You need not unanimously agree that defendant committed all the mechanisms listed in Instruction No. 5, first paragraph. [Emphasis added.]”

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

2. “[T]he Missouri Supreme Court approved revisions to the Notes on Use for the MAI applicable to a principal offense in order to address issues arising after Celis-Garcia. See MAI-CR 3d 304.02, Note 7 (effective July 1, 2013). Note 7 states that “[tjhere are two options when there are distinct criminal acts” based on Celis-Garcia. The Note continues, however, “[i]n a case consisting of evidence of the same repeated criminal act, ... [i]t is unclear whether the standard verdict directing instruction must be modified ... to ensure a unanimous verdict.” MAI-CR 3d 304.02, Note 7 (quoting Celis-Garcia, 344 S.W.3d at 157 n.8).”

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

3. “when there is evidence of multiple distinct criminal acts, each of which could serve as the basis for a criminal charge, but the defendant is charged with those acts in a single count.”

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