Commonwealth v. Simms’s Empirical Analysis

Citation profile

37 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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Because ‘ [n] o single litmus-paper test for constitutionally impermissible interrogation has been evolved . ,’ Culombe v. Connecticut, 367 U.S. 568, 601 , 81 S.Ct. 1860, 1878 , 6 L.Ed.2d 1037 (1961); Commonwealth v. Eiland, 450 Pa. 566, 573-574 , 301 A.2d 651, 654 (1973), we must in each case view the ‘totality of the circumstances.’ Commonwealth v. Hallowell, 444 Pa. 221, 226 , 282 A.2d 327, 329 (1971); Commonwealth v. Holton, 432 Pa. 11, 17 , 247 A.2d 228, 231 (1968). Circumstances which must be considered include the accused’s physical and mental condition, the delay between arrest and arraignment, the attitude of the police, and other ‘diverse pressures.’ Culombe, supra, 367 U.S. at 602 , 81 S.Ct. at 1879 ; Eiland, supra, 450 Pa. at 573-574 , 301 A.2d at 654 . Moreover, this Court has emphasized that when the question of voluntariness passes beyond the realm of physical coercion and into degrees of psychological coercion, the most careful attention will be afforded to any facts, circumstances, or events tending to overbear an accused’s will. Commonwealth ex rel. Butler v. Rundle, 429 Pa. 141, 149 , 239 A.2d 426, 430 (1968).””

   2 later decisions quote this exact passage
   e.g. Commonwealth v. Boyd · Commonwealth v. Kichline

2. ““ . . . Circumstances which must be considered include the accused’s physical and mental condition, the delay between arrest and arraignment, the attitude of the police, and other ‘diverse pressures.’ Culombe [v. Connecticut, 367 U.S. 568, at 602 ], 81 S.Ct. [1860] at 1879 [, 6 L.Ed.2d 1037 ] ; [Commonwealth v.] Eiland, 4 50 Pa. [566,] at 573-574, 301 A.2d [651,] at 654. * * * “Although this case does not turn on an application of Commonwealth v. Futch, 447 Pa. 389 , 290 A.2d 417 (1972), the unnecessary delay prior to arraignment is nevertheless relevant in determining the voluntariness of Simms’ confession. Commonwealth v. Eiland, 450 Pa. 566, 572 , 301 A.2d 651, 653 (1973); Commonwealth v. Koch, 446 Pa. 469, 474-475 , 288 A.2d 791, 793-794 (1972). Even prior to Futch an unnecessary-delay in arraignment could be considered in assessing the totality of the circumstances influencing an accused’s decision to confess. Commonwealth ex rel. Butler v. Rundle, 429 Pa. 141, 154-155 , 239 A.2d 426, 432-433 (1968).””

   1 later decision quote this exact passage
   e.g. Commonwealth v. Coach