State v. Smith’s Empirical Analysis

Citation profile

16 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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[I]f a state has jurisdiction over the crime, then a determination of the precise county [venue] for trial is less significant. [V]en-ue deals with convenience and location of trial rather than with the power of the court to hear the action in the first place.”

   2 later decisions quote this exact passage
   e.g. State v. Blooflat · County of Benton v. County of Stearns

2. ““Both the Minnesota and the United States Constitutions preserve the theory of territorial jurisdiction to some degree____ [T]he Sixth Amendment to the United States Constitution provides the right to a trial in ‘the state and district wherein the crime shall have been committed.’ (emphasis added). By use of the term ‘committed,’ both Consti tutions evidence an intent to maintain some form of territorial jurisdiction. “Statutes have been enacted in the various states that broaden the common law concept of territorial jurisdiction. These statutes basically have allowed a state to assume jurisdiction where any element of the crime was committed within its borders____ [A] state may now assume jurisdiction where the result or effect of the crime occurred within its boundaries. Thus, the state where a victim died (i.e., the result or effect of the murder) can assert jurisdiction over the murder under modern statutes. * * # * * * “However, even under the broad, modem statutes, some territorial aspects of jurisdiction remain. In order to withstand constitutional attack, some operative event, a triggering event if you will, must occur within the jurisdiction for the court to have power to act. The event needed, as required by the Minnesota and United States Constitutions, is that some part of the crime charged must be ‘committed’ within the jurisdiction.” (Emphasis supplied).”

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

3. ““However, the statute still requires that some territorial event be committed in Minnesota to confer jurisdiction. In [State v.] McCormick [, 273 N.W.2d 624 (Minn.1978) ], we expressly held that this statute does not totally abrogate ‘the limitations on extraterritorial jurisdiction which have long been recognized as the law of the land.’ 273 N.W.2d at 625 . On this basis, the court struck down a statute that made totally extraterritorial activity a crime in Minnesota. Id. 273 N.W.2d at 625 . We agree with appellant in this case that under McCormick , an attempt to exercise totally extraterritorial jurisdiction is contravened both by state and federal constitutional principles. Only if some part of the crime was committed within the State of Minnesota does the state have jurisdiction to punish the crime.””

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