Commonwealth v. Steele’s Empirical Analysis

Citation profile

88 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 94 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[Appellant contends] that he was prejudiced by trial counsel’s failures because the hair evidence was the only direct' evidence linking him to the crime. As such, adequate preparation and cross-examination, according to Appellant, would have likely led to a different result. We disagree. Appellant cannot demonstrate that he was prejudiced by trial counsel’s actions. Even if we assume that trial counsel’s preparation and cross-examination were inadequate, which we need not take a position on here, we cannot agree with Appellant that the outcome of the proceeding would likely have been different. See [Commonwealth v. Rios, 591 Pa. 588 , 920 A.2d 790 (Pa.2007) ]. Even if the jury disregarded the hair evidence, the evidence at. trial overwhelmingly demonstrated Appellant’s guilt. Three different eyewitnesses saw Appellant with the victims at, or near, the Millcraft Shopping Center. The first witness observed Appellant approach one of the victims and point to the car’s tire. The same witness watched as Appellant got into the drivers’ [sic] seat of the car. The second witness saw Appellant holding the door open for the other two victims as they entered the vehicle. A third witness identified Appellant driving the car around the time in question while his friend’s mother-in-law, Ms. Horner, was in the passenger seat. Appellant was then .seen driving the victim’s car later that day at the Elements Service Station. Testimony was also introduced regarding a burglary that occurred short”

   1 later decision quote this exact passage
   e.g. Steele v. Beard

2. “As a general proposition, an appellate court reviews the PCRA court’s findings to see if they are supported by the record and free from legal error. The court’s scope of review is limited to the findings of the PCRA court ... viewed in the light most favorable to the prevailing party. [[Image here]] To prevail on a claim that counsel was constitutionally ineffective, the [Appellant] must overcome the presumption of competence by showing that: (1) his underlying claim is of arguable merit; (2) the particular course of conduct pursued by counsel did not have some reasonable basis designed to effectuate his interests; and (3) but for counsel’s ineffectiveness, there is a reasonable probability that the outcome of the challenged proceedings would have been different. A failure to satisfy any prong of [this] test[, also referred to as the Pierce 4 test,] ... will require rejection of the claim.”

   1 later decision quote this exact passage
   e.g. 2009 Pa. Super. 154 - Commonwealth v. Fitzgerald

3. “The aggravating circumstance at issue requires that the defendant “committed” a killing while in the perpetration of a felony. Webster’s defines “commit” as follows: “[t]o do or perpetrate (an offense or crime).” Webster’s New World Dictionary (2d ed. 1996). The word “do” is thus defined: “to perform; to carry out; fulfill; to bring to completion; finish.” Id. The word “perpetrate” is defined as “to do or perform.” Id. Resolving ambiguity in the definition of the word “commit” in favor of the accused, as we must pursuant to the rule of lenity, we conclude that, as used in the statute at issue, the word “commit” requires a defendant to have performed the murder herself in the sense of bringing it to completion or finishing it.”

   1 later decision quote this exact passage
   e.g. Commonwealth v. Cox