Commonwealth v. Roebuck’s Empirical Analysis

Citation profile

20 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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[T]o be guilty of attempt, a defendant’s conscious objective must be to cause the result which would constitute the substantive crime. A person cannot attempt to commit a crime which requires that an unintended result occur, such as involuntary manslaughter, because it is logically impossible for one to intend to bring about an unintended result. Similarly, to be guilty of conspiracy, the defendant, upon entering an agreement, must intend that his conduct achieve the requisite criminal result. When the substantive crime requires an unintended result, a person cannot conspire to commit that crime because it is logically impossible to agree to achieve a specific result unintentionally. Contrary to the [appellant's] assertions, and unlike attempt or conspiratorial liability, accessorial liability does not require that a defendant act with the conscious objective to cause the result described by a statute. [[Image here]] [The accomplice statute] merely requires that a defendant have the mental state required for the commission of a crime while intentionally aiding another.”

   2 later decisions quote this exact passage · from the concurrence
   e.g. Commonwealth v. Fisher · Commonwealth v. Predmore

2. “Section [2.06(4)] thus prescribes that an accomplice may be held legally accountable where he is an “accomplice in the conduct” — or, in other words, aids another in planning or committing the conduct with the purpose of promoting or facilitating it — and acts with recklessness (i.e., the “kind of culpability ... sufficient for the commission of’ a reckless-result offense). To the extent any aspect of this accountability scheme is unclear, ample clarification is provided in the explanatory note and commentary. As a threshold matter, the commentary explains that the term “commission of the offense,” as used in Section 2.06(3), focuses on the conduct, not the result. See id. § 2.06, cmt. 6(b), at 310 (“Subsection 3(a) requires that the actor have the purpose of promoting or facilitating the commission of the offense, i.e., that he have as his conscious objective the bringing about of conduct that the Code has declared to be criminal[.]” (emphasis added)). This diffuses any impression that an accomplice must always intend results essential to the completed crime.... The commentary then points to the fourth subsection as supplying the essential culpability requirement, as follows: One who solicits an end, or aids or agrees to aid in its achievement, is an accomplice in whatever means may be employed, insofar as they constitute or commit an offense fairly envisaged in the purposes of the association. But when a wholly different crime has been committed, thus involving conduct not ”

   1 later decision quote this exact passage · from the concurrence
   e.g. Commonwealth v. Fisher

3. “We recognize that the Crimes Code does not contain the wealth of collateral explanatory material which accompanies the Model Penal Code, including the latter’s extensive notes and commentaries. Nevertheless, we believe the text of the Pennsylvania Statute is clear enough. In terms identical to those of Section 206 of the MPC, Section 306(d) of the Crimes Code directs the focus, for result-based elements, to the level of culpability required of a principal. See 18 Pa.C.S. § 306(d). In the present factual scenario, the purport is to avoid elevating a recklessness-oriented culpability requirement to a purposeful one relative to an accomplice.”

   1 later decision quote this exact passage · from the concurrence
   e.g. Commonwealth v. Fisher