54 Wash. App. 597 - State v. Leech’s Empirical Analysis

Citation profile

6 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““[ijt is not necessary that defendant’s act should have been the sole cause of the harm[;]... a contributory cause is sufficient.” (Italics omitted.) [Citations omitted.] Here, the arson was at least a contributory cause of Earhart’s death. But for the arson fire, Earhart would not have been exposed to the poisonous fumes that ultimately killed him. Moreover, a victim’s contributory negligence does not relieve a defendant of criminal responsibility for homicide unless it is a supervening cause of death, that is, the sole cause of death. State v. Judge, 100 Wash.2d 706, 718 , 675 P.2d 219 (1984).... Earhart’s alleged negligence in failing to use his breathing apparatus properly did not intervene in the chain of causation in such a way as to become the sole cause of his death. Earhart’s failure to use his breathing apparatus would not have resulted in his death if Leech had not set the arson fire. Thus, Leech’s conduct in setting the fire proximately caused Earhart’s death.”

   1 later decision quote this exact passage
   e.g. State v. Ruyle

2. “by the time Earhart arrived, the fire was well under way and [the defendant] had left the premises. Thus, [the defendant] did not cause Earhart's death 'in furtherance' of the arson.”

   1 later decision quote this exact passage
   e.g. 114 Wash. 2d 700 - State v. Leech