State v. Ryan’s Empirical Analysis

Citation profile

16 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(1) A person commits the offense of criminal contempt of court if: (a) The person recklessly engages in disorderly or contemptuous behavior, committed during the sitting of a court in its immediate view and presence, and directly tending to interrupt its proceedings or impair the respect due to its authority; [[Image here]] (3) The court may treat the commission of an offense under subsection (1) as a petty misdemeanor, in which case: (b) If the offense was committed in the immediate view and presence of the court, or under such circumstances that the court has knowledge of all of the facts constituting the offense, the court may order summary conviction and disposition; [[Image here]] (5) Whenever any person is convicted of criminal contempt of court or sentenced therefor, the particular circumstances of the offense shall be fully set forth in the judgment and in the order or warrant of commitment. In any proceeding for review of the judgment, sentence, or commitment, no presumption of law shall be made in support of the jurisdiction to render the judgment, pronounce the sentence, or order the commitment. A judgment, sentence, or commitment under subsection (3)(a) shall not be subject to review by appeal, but shall be subject to review in an appropriate proceeding for an extraordinary writ or in a special proceeding for review. [[Image here]]”

   2 later decisions quote this exact passage · from the majority
   e.g. State v. Tierney · 9 Haw. App. 249 - Wong v. Frank

2. “(3) The court may treat the commission of an offense under subsection (1) as a petty misdemeanor, in which case: (a) If the offense was committed in the immediate view and presence of the court, or under such circumstances that the court has knowledge of all of the facts constituting the offense, the court may order summary conviction and disposition; and (b) If the offense was not committed in the immediate view and presence of the court, nor under such circumstances that the court has knowledge of all of the facts constituting the offense, the court shall order the defendant to appear before it to answer a charge of criminal.contempt of court; the trial, if any, upon the charge shall be by the court without a jury; and proof of guilt beyond a reasonable doubt shall be required for conviction.”

   2 later decisions quote this exact passage · from the majority
   e.g. State v. Brown · 9 Haw. App. 249 - Wong v. Frank

3. “All of the offenses described in subsection (1) of the statute [HRS § 710-1077] require a degree of scienter and in order to have knowledge of all the facts constituting the offense it was necessary for the court to have knowledge that the offense was committed recklessly, knowingly, intentionally or with intent to interrupt the court’s proceeding, depending upon the clause of subsection (1) which the court deemed to be involved. It does not appear from the record that the court had knowledge of appellant’s state of mind in committing the offense, except to the extent disclosed by appellant’s statements to the court at the time of summary conviction. The mere fact of appellant’s absence, which was within the knowledge of the court, was not sufficient to enable it to infer the intent with which appellant absented himself.”

   1 later decision quote this exact passage · from the majority
   e.g. 9 Haw. App. 249 - Wong v. Frank