666 So. 2d 830 - Rowell v. State’s Empirical Analysis

Citation profile

9 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “"This position is inconsistent with Alabama cases in which evidence of drug sales or drug use was admitted as circumstantial evidence indicating that the defendant constructively possessed a controlled substance. See Robinette v. State , 531 So.2d 697 (Ala. 1988); Garner v. State , 606 So.2d 177 (Ala.Crim.App. 1992); Woods v. State , 437 So.2d 636 (Ala.Crim.App. 1983); Reed v. State , 401 So.2d 131 (Ala.Crim.App. 1981); Smith v. State , 351 So.2d 668 (Ala.Crim.App. 1977). Judge Bowen dissented from the judgment reversing Rowell's conviction. We agree with Judge Bowen's statement that `[e]vidence that the defendant was involved in the sale of drugs may be highly material and relevant in a prosecution for possession of a controlled substance.' [Rowell v. State] 666 So.2d [825] at 829 [(Ala.Cr.App. 1993)]. Judge Bowen stated, `In another context, [the Court of Criminal Appeals] has observed that possession and sale constitute "inevitably or necessarily incidental" conduct,' citing Tyler v. State , 587 So.2d 1238 , 1242 (Ala.Crim.App. 1991). See also Woods v. State , 437 So.2d 636 (Ala.Crim.App. 1983); Pinson v. State , 52 Ala. App. 444 , 446 , 293 So.2d 869 (1974)."”

   1 later decision quote this exact passage
   e.g. 718 So. 2d 731 - Tolbert v. State

2. “Alabama case law recognizes that large sums of cash are relevant and material to a charge of. . . . possession of a *Page 11 controlled substance,”

   1 later decision quote this exact passage
   e.g. 72 So. 3d 707 - T.A.P. v. State of Alabama.