Sims v. State’s Empirical Analysis
1984
Citation profile
15 state decisions
How this case has been cited
Cited by 15 later decisions — most recently February 2012
15 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 Miller v. State · Gramm v. State
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Appellant contends that the surgery on the fractured mandible was unnecessary and worsened the victim’s condition; and as a result, the intervening cause of surgery relieves him of criminal responsibility for the victim’s death. This argument must fail. It was determined at trial that the victim was in stable condition before the surgery and that the surgery was necessary in order to prevent a possible life threatening infection. In order for an intervening cause to break the chain of criminal responsibility, it must be so extraordinary that it would be unfair to hold the appellant responsible for the actual result. Here, the intervening cause of surgery was not extraordinary because the injury necessitated it. As a result it is fair to hold the appellant responsible for the victim’s death. There is sufficient evidence from which the jury could infer that the beating inflicted upon the victim contributed mediately or immediately to his death.”
3 later decisions quote this exact passage“[Elven when cause in fact is established, it must be determined that any variation between the result intended (with intent crimes) or hazarded (with reckless or negligent crimes) and the result actually achieved is not so extraordinary that it would be unfair to hold the defendant responsible for the actual result. Variations may occur (a) as to the person who is harmed, or (b) as to the manner in which the harm oceurs, or (c), in felony murder and misdemeanor-manslaughter cases, as to the type of harm.”
1 later decision quote this exact passagee.g. Duncan v. State
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.