75 Wash. App. 301 - State v. Strohm’s Empirical Analysis
1994
Citation profile
2 district · 35 state decisions
How this case has been cited
Cited by 37 later decisions — most recently August 2015 · most notably State v. Michielli (1997), State v. Smith (2007)
2 district · 35 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 Patillo v. Georgia · 110 Wash. 2d 326 - In Re the Personal Restraint of Jeffries · 116 Wash. 2d 154 - State v. Schulze · 71 Wash. App. 345 - State v. Bland · 62 Wash. App. 755 - State v. Peerson
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he placement and repetition of the word “knowingly’ suggests that the legislature intended two means. The first “knowingly’ clearly relates to all seven terms in the first part of the statute ... as a group. . . . Similarly, the phrase “the theft of property for sale to others” relates to the entire group. Treating these terms as a group indicates that they represent multiple facets of a single means of committing the crime. ... If the statute described eight means, there would be no need to use the word “knowingly” again. [Further], the first group of seven terms relate to different aspects of a single category of criminal conduct - facilitating or participating in the theft of property so that it can be sold. As a result, these terms appear to be definitional. They are examples of such facilitation or participation.... And trafficking in stolen property involves a second, separate category - transferring possession of property known to be stolen - defined separately in [the definitional section of the statute].”
2 later decisions quote this exact passage“The various ways a person can “traffic” under RCW 9A.82.010(10) are merely factual circumstances which support the traffics alternative under RCW 9A.82.050(2). Thus, there is no requirement that the jurors agree on the facts supporting the “traffics” alternative means of committing the offense of “Trafficking in stolen property”.[ 16 ]”
2 later decisions quote this exact passage“`that definition statutes do not create additional alternative means,”
2 later decisions quote this exact passagee.g. State v. Marko · State v. Smith
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.