Holbrook v. Commonwealth’s Empirical Analysis
1991
Citation profile
12 state decisions
How this case has been cited
Cited by 12 later decisions — most recently June 2012
12 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 Gall v. Commonwealth · McClellan v. Commonwealth · Wellman v. Commonwealth · Shannon v. Commonwealth · Hamilton v. Commonwealth
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"In Shannon , we recognized that an individual may intentionally commit murder while acting under a wanton or reckless belief, and that the actor's subjective belief may be unreasonable when viewed by an objective standard. Shannon, supra at 550-51 . . . . If the jury believes from the evidence that the defendant's claimed need for self-defense is objectively reasonable under the circumstances, then it becomes a complete defense. However, if the justification is not reasonable, then the defendant can only be convicted under Shannon of either the offenses of manslaughter in the second degree or reckless homicide, depending upon the jury's determination of the defendant's state of mind at the time of the act. Shannon, supra at 552 . . . . [T]he gist of the reasoning is that `[a] subjective belief in the need for self-defense, which is objectively wanton or reckless, is a `circumstance' falling within the definition of wanton or reckless behavior, punishable under Manslaughter II or Reckless Homicide. . . .' Id. at 551-52 ."”
1 later decision quote this exact passage“Extreme emotional disturbance is a temporary state of mind so enraged, inflamed, or disturbed as to overcome one’s judgment, and to cause one to act uncontrollably from the impelling force of the extreme emotional disturbance rather than from evil or malicious purposes. It is not a mental disease in itself, and an enraged, inflamed, or disturbed emotional state does not constitute an extreme emotional disturbance unless there is a reasonable explanation or excuse therefor, the reasonableness of which is to be determined from the viewpoint of a person in the defendant’s situation under circumstances as [the] defendant believed them to be.”
1 later decision quote this exact passage“An instruction on murder need not require the jury to find that the defendant was not acting under the influence of extreme emotional disturbance unless there is something in the evidence to suggest that he was, thereby affording room for a reasonable doubt in that respect.”
1 later decision quote this exact passagee.g. Coffey v. Messer
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.