State v. Mane’s Empirical Analysis
1989
Citation profile
13 state decisions
How this case has been cited
Cited by 13 later decisions — most recently April 2022
13 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 Neal v. State of California · Killian v. United States · Bisso v. Inland Waterways Corp. · Vereen v. United States · State v. Couture
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he term “same act” as used in section 76-1-402(1) should be read in conjunction with the latter statutory language in the same section, pertaining to offenses under different provisions of the code which may be violated by a single act. As implied in James , for example, the single act of shooting Brown could be chargeable as first degree homicide, negligent homicide or manslaughter. However, the shooting of a second victim, albeit with the same bullet, is not an offense “which may be punished in different ways under the different provisions of this code,” but is punishable as a separate offense. We do not believe that the legislature intended to preclude greater punishment where multiple victims exist.... We, therefore, hold that “act” as used in section 76-1-402(1) includes not only volitional acts of a defendant, but also the number of victims, as each is acted upon by a defendant.... Each striking was an “act” constituting a separate offense, allowing separate charges and convictions.”
2 later decisions quote this exact passagee.g. State v. Gambrell · State v. Ganal“[Wjhen the same act of a defendant under a single criminal episode shall establish offenses which may be punished in different ways under different provisions of this code, the act shall be punishable under only one such provision.”
2 later decisions quote this exact passage“whether a single criminal act resulting in multiple victims constitutes a single offense or multiple offenses”
1 later decision quote this exact passage
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.