80 N.C. App. 103 - State v. Watson’s Empirical Analysis
1986
Citation profile
10 state decisions
How this case has been cited
Cited by 10 later decisions — most recently August 2003
10 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 103 S. Ct. 247 - Beneficial Finance of Kansas, Inc. v. United States · Poythress v. Duncan · State v. Craig · State v. Dooley · State v. Lampkins
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The element of felonious possession requiring the property to be valued at more than $400.00 (now $1,000.00) implicitly includes the requirement that there be at least one single point in time when the defendant possessed an amount of goods valued at more than $400.00 (now $1,000.00). Otherwise, the State’s burden of proof on a charge of felonious possession of stolen goods would be no greater than to present circumstantial evidence of two or more non-felonious possessions, add them together, and obtain a felony conviction. We do not believe the legislature intended this when it enacted N.C. Gen. Stat. Sec. 14-71.1 (1977). Rather, G.S. Sec. 14-71.1 “was apparently passed to provide protection for society in those incidents when the State does not have sufficient evidence to prove who committed a larceny, or the elements of receiving.” State v. Kelly, 39 N.C. App. 246, 248 , 249 S.E.2d 832, 833 (1978). Nonetheless, it is incumbent on the State to prove all the elements of felonious possession in order to obtain a conviction on that charge. The jury should have been instructed that the State must prove beyond a reasonable doubt that defendant possessed an amount of goods valued at more than $400.00 at one point in time.”
1 later decision quote this exact passage“Implicit in this requirement is that the trial court must correctly declare and explain the law as it relates to the evidence. The failure of the court ... to correctly instruct the jury on substantial features of the case arising on the evidence [constitutes] error for which [the] defendant is entitled to a new trial.”
1 later decision quote this exact passage“every substantial feature of the case arising on the evidence must be presented to the jury even without a special request for instructions on the issue.”
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.