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← 444 Mass. 289 - Commonwealth v. Lyons

Commonwealth v. Lyons’s Empirical Analysis

2005

Citation profile

21
cited by 21 later decisions
1
states following
October 2021
most recently cited

5 federal appellate · 4 district · 12 state decisions

How this case has been cited

Cited by 21 later decisions — most recently October 2021

5 federal appellate · 4 district · 12 state decisions

110200520102020decided

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 Young v. United States ex rel. Vuitton · Commonwealth v. Welansky · Commonwealth v. Azar · Commonwealth v. Sires · Commonwealth v. Sanna

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

  1. “[T]he judge is not to sit as a 'second jury.' " Commonwealth v. Chhim , 447 Mass. 370 , 381 (2006), quoting Commonwealth v. Keough , 385 Mass. 314 , 321 (1982). "[T]o justify a reduction in the verdict, there must be some weakness in the critical evidence ... or some weakness in the evidence coupled with trial error.”
    2 later decisions quote this exact passage
  2. “The judge admitted the photographs only after the Commonwealth had laid a foundation indicating that the photographs were relevant to establishing the severity of the [babyj’s injuries. [Lyons] argues that this was an abuse of discretion because the nature, extent, and cause of the fatal injuries were not issues before the jury. While we agree with [Lyons] that the photographs were disturbing, we do not agree that they lacked relevance. A critical issue in the case was the amount of force used to shake the [baby]. As the nature of the injuries supported an inference concerning the amount of force used to inflict the injuries, the photographs were relevant to that issue. Additionally, the final photograph admitted, showing no injury to the back of the [baby]’s head, was relevant to contradict [Lyons’s] testimony that the [baby] hit his head in the bathtub. 10 Furthermore, the judge appropriately mitigated any potential prejudice by cautioning the jury not to be affected by the nature of the photographs and by instructing them that the photographs were to be used only to draw attention to a clinical medical status or the nature and extent of the [baby]’s injuries.”
    1 later decision quote this exact passage
  3. “[a] fine line distinguishes murder in the second degree based on third prong malice from the lesser included offense of involuntary manslaughter.”
    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.