Commonwealth v. Parmar’s Empirical Analysis
1998
Citation profile
28 state decisions
How this case has been cited
Cited by 29 later decisions — most recently August 2020 · most notably Commonwealth v. Ludwig (2005), Commonwealth v. Lussi (2000)
28 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
Applies 18 U.S.C. § 641 (Livestock Fraud Protection Act)
Relies on Morissette v. United States · Staples v. United States · Commonwealth v. Koczwara · Commonwealth v. Mikulan · United States v. Forsythe
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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Absolute criminal liability statutes are an exception to the centuries old philosophy of criminal law that imposed criminal responsibility only for an “act coupled with moral culpability.” Commonwealth v. Weinstein, 499 Pa. 106, 116 , 451 A.2d 1344, 1348 (1982). A criminal statute that imposes absolute liability typically involves regulation of traffic or liquor laws. E.g., Commonwealth v. Mikulan, 504 Pa. 244 , 470 A.2d 1339 (1983) (upholding the imposition of absolute criminal liability where the Commonwealth failed to charge or prove culpability pursuant to 75 Pa.C.S. § 3731(a)(4), driving with a blood alco- hoi of .10%, and the defendant was sentenced to less than ninety days imprisonment); Commonwealth v. Koczwara, 397 Pa. 575 , 155 A.2d 825 (1959) (upholding absolute vicarious criminal liability for the sale of liquor to minors); Commonwealth v. Rudinski, 382 Pa.Super. 462 , 555 A.2d 931 (1989) (absolute liability for parking violations); Commonwealth v. Robinson, 497 Pa. 49 , 438 A.2d 964 (1981) (statutory rape is a strict criminal liability crime)[.]”
1 later decision quote this exact passage · from the concurrence“In the absence of plain legislative intent, we must consider the purpose for the ... statutes, the severity of punishment and its effect on the defendant’s reputation and, finally, the common law origin of the crimes to determine whether the legislature intended to impose absolute criminal liability. See Staples v. United States, 511 U.S. 600 , 114 S.Ct. 1793 , 128 L.Ed.2d 608 (1994); Commonwealth v. Mikulan, 504 Pa. 244 , 470 A.2d 1339 (1983) (Zappala, J., concurring) (quoting Holdridge v. United States, 282 F.2d 302 (8th Cir.1960)).”
1 later decision quote this exact passage · from the majority“Whenever a general provision in a statute shall be in conflict with a special provision in the same or another statute, the two shall be construed, if possible, so that effect may be given to both. If the conflict between the two provisions is irreconcilable, the special provisions shall prevail and shall be construed as an exception to the general provision, unless the general provision shall be enacted later and it shall be the manifest intention of the General Assembly that such general provision shall prevail.”
1 later decision 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.