Sattiewhite v. State’s Empirical Analysis

Citation profile

63 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 65 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In the determination whether the evidence was sufficient to warrant a jury charge on voluntary manslaughter, this Court must consider all relevant facts and circumstances. It is not enough that appellant acted mad or upset, the evidence must also show that the anger was the result of an act of provocation on the part of the deceased or a third party acting in concert with the deceased. In cases where this Court has held the evidence was sufficient to warrant such a charge, a distinguishing factor tends to be that the deceased and the appellant had engaged in some sort of altercation or argument which immediately escalated into a killing. See Humphries v. State, 615 S.W.2d 737 (Tex.Cr.App.1981) (stabbing in the course of a heated argument); Schoelman v. State, 644 S.W.2d 727 (Tex.Cr.App.1983) (shooting after an argument over a ring). However, this Court has distinguished cases where the passion was not sudden. Hobson [v. State, 644 S.W.2d 473 (Tex.Cr.App.1983) ], supra. (Charge on voluntary manslaughter not warranted where altercation took place in the morning and the stabbing took place in the evening.) Jenkins v. State, 740 S.W.2d 435 (Tex.Cr.App.1983). (Killing resulted after highway chase and altercation; defendant not entitled to a charge on voluntary manslaughter because fear alone is not enough to raise sudden passion.)”

   2 later decisions quote this exact passage
   e.g. Nobles v. State · Travis v. State

2. “(a) A person commits an offense if he causes the death of an individual under circumstances that would constitute murder under Section 19.02 of this code[ 16 ] except that he caused the death under immediate influence of sudden passion arising from adequate cause. (b) “Sudden passion” means passion directly caused by the individual killed or another acting with the person killed which passion arises at the time of the offense and is not solely the result of former provocation. (c) “Adequate cause” means cause that would commonly produce a degree of anger, rage, resentment, or terror in a person of ordinary temper, sufficient to render the mind incapable of cool reflection. * * * ⅜ * *”

   1 later decision quote this exact passage
   e.g. Nobles v. State

3. “then there shall be no answer for that special issue. Id. This Court additionally noted that the jury did not exhibit any confusion in reaching a unanimous verdict, nor was there any correspondence between the jury and the trial court during punishment deliberations. Id. at 279 . In the instant cause, the punishment jury charge contained instructions similar to those in Sattiewhite, supra , including explanations: that before any special issue may be answered”

   1 later decision quote this exact passage
   e.g. Clark v. State