Commonwealth v. Eiland’s Empirical Analysis
1973
Citation profile
191 state decisions
How this case has been cited
Cited by 193 later decisions — most recently January 2020 · most notably Commonwealth v. Kichline (1976), Commonwealth v. Sullivan (1977)
191 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 Culombe v. Connecticut · Spano v. People of the State of New York · Commonwealth v. Futch · Commonwealth Ex Rel. Butler v. Rundle · Commonwealth v. Burdell
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 193 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“". . . Although more than mere association must be shown, `"[a] conspiracy may be inferentially established by showing the relation, conduct, or circumstances of the parties, and the overt acts on the part of co-conspirators have uniformly been held competent to prove that a corrupt confederation has in fact been formed: . . ."' Commonwealth v. Neff [ 407 Pa. 1 , 179 A.2d 630 (1962)] . . . at 6, 179 A.2d at 632 , quoting Commonwealth v. Horvath, 187 Pa.Super. 206, 211 , 144 A.2d 489, 492 (1958). "Moreover, a co-conspirator is not relieved of liability because he is not present at the execution of the crime. Commonwealth v. Burdell, 380 Pa. 43 , 110 A. 2d 193 (1955). As we noted in Commonwealth v. Thomas, 410 Pa. 160, 165 , 189 A.2d 255, 258 (1963): `Where the existence of a conspiracy is established, the law imposes upon a conspirator full responsibility for the natural and probable consequences of acts committed by his fellow conspirator or conspirators if such acts are done in pursuance of the common design or purpose of the conspiracy. Such responsibility attaches even though such conspirator was not physically present when the acts were committed by his fellow conspirator or conspirators and extends even to a homicide which is a contingency of the natural and probable execution of the conspiracy, even though such homicide is not specifically contemplated by the parties ( Commonwealth v. Spardute, 278 Pa. 37, 50 , 122 A. 161 ).'"”
4 later decisions quote this exact passage · from the majority“"[T]his Court has emphasized that when `[t]he questions in the voluntariness area have passed beyond the physical coercion stage to the much more difficult area of psychological coercion ... a close analysis of all the surrounding circumstances is necessary,' Commonwealth ex rel. Butler v. Rundle, [ 429 Pa. 141 , 239 A.2d 426 (1968)], and that `the test for any involuntary confession, must concern itself with those elements impinging upon a defendant's will.' Commonwealth v. Baity, 428 Pa. 306 , 315 n. 7, 237 A.2d 172 , 177 n. 7 (1968). Thus in the instant case we must weigh all the factors influencing appellant's will at the time he made his statement. The record evinces uncontradicted evidence that appellant, a 20-year-old with a tenth grade education, was isolated for several periods of time; that upon his initial interrogation he refused to admit involvement in the shooting; that eleven hours later when told by the police he would get more lenient treatment if he confessed, he signed an incriminating statement; and that he was not arraigned until some twenty-five hours after arrest. "The combination of all these factors based on the Commonwealth's uncontradicted evidence constituted a subtle but nonetheless powerful form of impermissible psychological coercion... . We conclude that appellant's signed statement was involuntary and should therefore have been suppressed." 301 A.2d at 654-655 .”
4 later decisions quote this exact passage · from the majority“. . . Although more than mere association must be shown, `”
2 later decisions quote this exact passage · from the majority
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.