People v. Jaffray’s Empirical Analysis
1994
Citation profile
4 federal appellate · 2 state decisions
How this case has been cited
Cited by 14 later decisions — most recently May 2015
4 federal appellate · 2 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.
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“He clearly intended to confine the victim to the car and to force her to drive. While the victim could have unlocked the doors, by locking the doors defendant impeded her ability to exit and forced her to remain in the driver’s seat. While unlocking the doors would have taken only a moment, restraint does not require any particular length of time [under MCL § 750.349b(3)(a) ]. We also note that while refraining from physical force, defendant exploited the situation to confine the victim to her car. Particularly, the victim’s baby was in the backseat strapped in a car seat, and exiting would have required the victim to leave her daughter in the ear. Also, while defendant did not have a weapon, based upon his placement of his hands, the victim feared he might be armed. Finally, defendant told the victim he was being chased by someone trying to kill him. In actuality, he was being pursued by Wal-Mart security personnel. This lie led the victim to believe there was a danger of violence outside the car and compelled her to follow defendant’s orders. Considering the evidence in a light most favorable to the prosecution we conclude the evidence was sufficient to establish defendant’s restraint of the victim.”
1 later decision quote this exact passage“(1) forcibly confining or imprisoning any other person within the state against his will; (2) secretly confining or imprisoning any other person within the state against his will; (8) forcibly carrying or sending such person out of the state; (4) forcibly seizing or confining, or inveigling or kidnapping any other person with intent to extort money or other valuable thing thereby; (5) forcibly seizing or confining, or inveigling or kidnapping any other person with intent to cause such person to be secretly confined or imprisoned in the state against his will; or (6) forcibly seizing or confining, or inveigling or kidnapping any other person with intent to cause such person to be in any way held to service against his will.”
1 later decision quote this exact passage“where appropriate,” asportation of the victim is a judicially required element of forcible confinement kidnapping under Michigan law. In this way, the court distinguished forcible confinement kidnapping from other, minor crimes and preserved the constitutionality of the statute. Id. The court further held that asportation or movement of the victim is not sufficient if it is merely incidental to the commission of an underlying lesser crime. Id. In Wesley, the court explained that asportation”
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.