Commonwealth v. Petzold’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. “Simply put, sentencing entrapment/manipulation is difficult to prove; it is not established simply by showing that the idea originated with the government or that the conduct was encouraged by it, ... or that the crime was prolonged beyond the first criminal act ... or exceeded in degree or kind what the defendant had done before.”

   2 later decisions quote this exact passage
   e.g. 2000 Pa. Super. 270 - Commonwealth v. Adams · 2013 Pa. Super. 118 - Commonwealth v. Toritto

2. “Sentencing entrapment or manipulation is a doctrine developed and adopted in several Federal Circuit Courts of Appeal. It occurs when a defendant, al though predisposed to commit a minor or lesser offense, is entrapped in committing a greater offense subject to greater punishment. It often is asserted in narcotics matters, typically reverse sting cases, in which government agents determine the amount of drugs a target will purchase. Sentencing entrapment or manipulation is similar to traditional notions of entrapment in that it requires extraordinary misconduct by the government. However, it differs from classic entrapment in that it is not a complete defense to criminal charges and, therefore, cannot serve as a basis for acquittal. Instead, it provides a convicted defendant the opportunity for a reduced sentence, typically in the form of a downward departure from the sentencing guidelines.”

   1 later decision quote this exact passage
   e.g. 2013 Pa. Super. 118 - Commonwealth v. Toritto

3. “[wjhile the specific amount of illicit drugs was not Appellant’s idea, his interest in obtaining the proffered amount is clear from the transcript. Appellant needed little urging from the Cl before agreeing to take five pounds of the drug. His reference to another deal which had the potential to generate four thousand dollars toward this purchase, coupled with his insistence that he “could move five,” contradict his argument that he was not predisposed to make such a large purchase. Further the ease and promptness with which he accepted the Cl’s offer belie his assertion that the government ensnared him in a deal which resulted in a stricter sentence than he deserved.”

   1 later decision quote this exact passage
   e.g. 2011 Pa. Super. 60 - Commonwealth v. Kittrell