51 Wash. App. 436 - State v. Noel’s Empirical Analysis
1988
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently January 2012
14 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 94 Wash. 2d 216 - State v. Green · 101 Wash. 2d 566 - State v. Petrich · 110 Wash. 2d 403 - State v. Kitchen · 108 Wash. 2d 662 - State v. Hodgson · 99 Wash. 2d 663 - State v. Valladares
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.
“`you must unanimously agree that at least one particular act has been proved beyond a reasonable doubt'”
2 later decisions quote this exact passage“Appellant argues the instruction can be read to mean the jury could convict as long as each juror was convinced at least one of the acts was proved beyond a reasonable doubt, even if each juror was convinced as to a different act. We think the less strained reading, and the one an ordinary juror would give the instruction, is that unanimous consensus was required as to which act was proved. In the operative clause, "you must unanimously agree that at least one particular act has been proved beyond a reasonable doubt", the subject is the plural you, meaning all the jurors. The verb phrase requires unanimous agreement among them. Finally, the object of their agreement is that one particular act has been proved. The phrase one particular act, in conjunction with the plural you, asks the jury as a whole to focus on a single act. Consequently, the ordinary reasonable juror would read the clause to mean the jury must unanimously decide the same act has been proved beyond a reasonable doubt.”
1 later decision quote this exact passage“[t]he issue before us . . . is not whether it is possible to interpret [the] instruction . . . to mean one can be convicted without unanimity as to the act proved, but whether the ordinary juror would so interpret it.”
1 later decision quote this exact passagee.g. State v. Moultrie
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.