Commonwealth v. Spotz’s Empirical Analysis

Citation profile

4 federal appellate · 136 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 141 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “To prevail on his ineffectiveness claims, Appellant must plead and prove by a preponderance of the evidence that (1): the underlying legal claim has arguable merit; (2) counsel had no reasonable basis for his action or inaction; and (8) Appellant suffered prejudice because of counsel’s action or inaction. With regard to the [reasonable basis] prong, we will conclude that counsel’s chosen strategy lacked a reasonable basis only if Appellant proves that an alternative not chosen offered a potential for success substantially greater than the course actually pursued. To establish the [prejudice] prong, Appellant must show that there is a reasonable probability that the outcome of the proceedings would have been different but for counsel’s action or inaction.”

   4 later decisions quote this exact passage
   e.g. 2017 Pa. Super. 164 - Commonwealth v. Lawrence · 2017 Pa. Super. 133 - Commonwealth v. Brown

2. “The following are mitigating circumstances which, as you will recall, the defense must prove by a preponderance of the evidence: The age of the defendant at the time of the crime is considered under this statute [] a mitigating circumstance. And any other evidence of mitigation concerning the character and record of the defendant and the circumstances of his offense which you as jurors may find. So I will read those again. The age of the defendant at the time of the crime, and any other evidence of mitigation concerning the character and record of the defendant and the circumstances of his offense. Now, you will be provided with a verdict slip here momentarily. * * * As I told you earlier, you must agree unanimously, that is, all of you, on one of the two general findings before you can sentence the defendant to death. If you do agree on one of the two general findings, you must return a sentence of death. The findings are [ ] that there is at least one aggravating circumstance and no mitigating circumstances, or the aggravating circumstance[s] outweigh any mitigating circumstances.... If you all agree on either one of the two general findings, then you can and must sentence the defendant to death. When voting on the general findings, you are to regard a particular aggravating circumstance as present only if all of you agree that it is present. This is the second distinction. Aggravating circumstances must be proven unanimously beyond a reasonable doubt. On the other hand, ea”

   2 later decisions quote this exact passage · from the majority
   e.g. Commonwealth v. Watkins · Commonwealth v. Ballard

3. “Under Brady , “a prosecutor has an obligation to disclose all exculpatory information material to the guilt or punishment of an accused, including evidence of an impeachment nature.” Commonwealth v. Spotz [ 610 Pa. 17 ], 18 A.3d 244, 275-76 (Pa.2011) (citation omitted). To establish a Brady violation, appellant must demonstrate: the evidence at issue was favorable to him, because it was either exculpatory or could have been used for impeachment; the prosecution either willfully or inadvertently suppressed the evidence; and prejudice ensued. Id., at 276 (citation omitted). “The evidence at issue must have been ‘material evidence that deprived the defendant of a fair trial.’ ... ‘Favorable evidence is material ... if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.’ ” Id. (citations omitted).”

   2 later decisions quote this exact passage
   e.g. Commonwealth, Aplt. v. Solano, R. · Commonwealth v. Champney