Wells v. State’s Empirical Analysis
1984
Citation profile
1 district · 31 state decisions
How this case has been cited
Cited by 32 later decisions — most recently July 2023 · most notably People v. Harlan (2000), Dancer v. State (1986)
1 district · 31 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on United States v. Bailey · Toussie v. United States · 43 Cal. App. 3d 823 - People v. Lovercamp · Commonwealth v. Stanley · Juneby v. State
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) The prisoner is faced with a specific threat of death, forcible sexual attack or substantial bodily injury in the immediate future; (2) There is no time for a complaint to the authorities or there exists a history of futile complaints which make any result from such complaints illusory; (3) There is no time or opportunity to resort to the courts; (4) There is no evidence of force or violence used towards prison personnel or other “innocent” persons in the escape; and (5) The prisoner immediately reports to the proper authorities when he has attained a position of safety from the immediate threat.”
3 later decisions quote this exact passagee.g. Spakes v. State · State v. Tuttle“Alaska courts have long recognized that a major risk generated by an escape is potential harm caused by the escapee while at large. See, e.g., Alex v. State, 484 P.2d 677, 685 (Alaska 1971). In Alex, the court rejected an equal protection challenge to the statutory scheme imposing greater penalties on felons who escape than on misdemeanants. The court said: “The legislature could reasonably have believed that persons convicted of felonies which are generally more serious crimes than misdemeanors, present a greater threat to the public. Thus, a greater effort to deter their escape may reasonably be made.” Id. ... We therefore conclude that escape under Alaska law is a continuing offense.”
1 later decision quote this exact passagee.g. State v. Martinez“declin[ed] to adopt a detailed statutory formulation [of the necessity defense]. Instead, the necessity defense was incorporated into the Revised [Criminal] Code “to the extent permitted by common law” [subject to] the qualifications described in subsections (1) and (2) [of AS 11.81.320(a) ]. The [Criminal Code Revision] Subcom-mission concluded ... that “it is more appropriate to leave this issue to the judiciary[.] [T]he rarity of the defense and the imponderables of the particulars of specific cases convinces us that the courts can better define and apply this defense than can be done through legislation.””
1 later decision quote this exact passagee.g. Seibold v. State
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.