428 Pa. Super. 413 - Commonwealth v. Sattazahn’s Empirical Analysis
1993
Citation profile
41 state decisions
How this case has been cited
Cited by 43 later decisions (2 by the Supreme Court) — most recently March 2021 · most notably Commonwealth v. Grant (2002), Sattazahn v. Pennsylvania (2003)
41 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 Sandstrom v. Montana · Leary v. United States · Francis v. Franklin · Needler v. Valley National Bank of Arizona · Turner 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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The cases further hold that the specific intent to kill “can be formulated in a fraction of a second.” A specific intent to kill can be inferred from the circumstances surrounding an unlawful killing. Because a person generally intends the consequences of his act, a specific intent to kill may be inferred from the fact that the accused used a deadly weapon to inflict injury to a vital party of the victim’s body. (Citations omitted).”
2 later decisions quote this exact passage · from the majority“Since [the presumption of innocence] is with the defendant not only at the beginning of the trial but throughout all its stages, and even while the jury is considering its verdict, it is obvious that no contrary presumption can be indulged. Hence it has been said that all presumptions independent of evidence are in favor of innocence. Watkins v. Prudential Insurance Co., 315 Pa. 497 , 173 A. 644 , 95 A.L.R. 869 [ (1934) ]. It is the law that in a criminal case, unlike a civil case, no binding instruction may be given in favor of the prosecution. This is true whether the evidence upon which the prosecution rests is oral or documentary and is equally true no matter how strong the proof proffered by the prosecution may be. It is because of this never-shifting burden upon the Common wealth to prove every essential element of the charge it makes against the defendant that it cannot logically be said that the Commonwealth has the burden to prove the presence of such element while the defendant, at the same time, has the burden of proving its absence. [Commonwealth v. Bonomo, 396 Pa. 222, 229-30 , 151 A.2d 441, 445-46 (1959) ]. In keeping therewith, the Supreme Court has “held that, “virtually all so-called “criminal presumptions” are really no more than permissible inferences.’ ” Commonwealth v. Mason, 483 Pa. 409, 413 , 397 A.2d 408, 411 (1979), (quoting Commonwealth v. DiFrancesco, [ 458 Pa. 188 , 193 n. 3, 329 A.2d 204 , 208 n. 3 (1974) ].) When dealing with a statutory presumpt”
1 later decision quote this exact passage · from the majority“We likewise find a rational connection between the licensing or failure to license a firearm and the intent with which a person acts in using that firearm. The legislature has recognized a distinction between prohibited offensive weapons which have no peaceful purpose and “shall not be allowed to exist in our society”, Commonwealth v. Adams, 245 Pa.Super. 431, 436 , 369 A.2d 479, 482 (1976); and those which have peaceful as well as lethal potentialities. Cf. Commonwealth v. Stewart, 343 Pa.Super. 514, 532 , 495 A.2d 584, 593 (1985). The former are banned absolutely because criminal usage is conclusively presumed, while the latter are allowed, if licensed. The obtaining of a license is tantamount to an acknowledgment that the possession is for lawful purposes; the failure to obtain a license suggests the opposite. One who envisions no criminal purpose for the firearm is unlikely to refuse, if required, to declare his ownership of that weapon to the proper authorities, while one who harbors criminal intentions will. This is not to say that in every instance the lack of a license suggests criminal intent, but rather that a lack of required license is simply another piece of circumstantial evidence from which the true intent of the user of a firearm might be ascertained in a given situation.”
1 later decision quote this exact passage · from the majoritye.g. Commonwealth v. Hall
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.