Commonwealth v. Bryant’s Empirical Analysis
1987
Citation profile
31 state decisions
How this case has been cited
Cited by 31 later decisions — most recently October 2018 · most notably Commonwealth v. Hughes (1989), Commonwealth v. Dillon (2007)
31 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 Commonwealth v. Wable · Commonwealth v. Morris · Commonwealth v. Claypool · Commonwealth v. Banks · Commonwealth v. Holcomb
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Ejvidence of other crimes is admissible when it tends to prove a common scheme, plan or design embracing the commission of two or more crimes so related to each other that proof of one tends to prove the others or to establish the identity of the person charged with the commission of the crime on trial, — in other words where there is such a logical connection between the crimes that proof of one will naturally tend to show that the accused is the person who committed the other.”
3 later decisions quote this exact passage · from the majority“[W]e cannot conclude that the factual predicates are so distinctly similar that one could naturally conclude that both crimes were perpetrated by the same individual. Although there exist[ ] general similarities, the elements of common scheme or design are lacking. It is true that both crimes occurred at approximately the same time of night and within a one and one-half block of the Appellant’s home. However, the victims’ ages varied drastically, in addition to the victims being of different races. Furthermore, the evidence was questionable as to whether [ ]. Steckle was sexually assaulted although [] Phillips was assaulted. It was also widely known.that [] Steckle lived alone while [ ] Phillips lived with her three-year-old son. Furthermore, while [.] Steckle was brutally and viciously injured in the face, head, body, arms and legs, [] Phillips was punched only in the head.. [ ] Steck-le was found lying on the ground floor, while [] Phillips was dragged to the second-floor bedroom. Finally, a television, radio, and ring were taken from [ ] Steckle’s home, while only thirty dollars in cash was taken from [,] Phillips even though a portable .television .and radio were in full sight of the burglar. While it is true that' every element of the crimes need not be identical to constitute a ‘signature crime’, the details relied upon must be sufficiently unique to suggest that the crimes were committed by the same person. Based upon the similarities and differences between these two ”
2 later decisions quote this exact passage · from the majority“so nearly identical in method as to earmark them as the handiwork of the accused. Here much more is demanded than the mere repeated commission of crimes of the same class, such as repeated burglaries or thefts. The device used must be so unusual and distinctive as to be like a signature____ [Moreover], ‘[t]here must be such a high correlation in the details of the crimes that proof that the defendant committed one makes it very unlikely that anyone else but the defendant committed the others.’”
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.