Ex Parte Edwards’s Empirical Analysis
2001
Citation profile
1 federal appellate · 41 state decisions
How this case has been cited
Cited by 44 later decisions (1 by the Supreme Court) — most recently December 2015 · most notably 843 So. 2d 885 - Allstate Ins. Co. v. Kaklamanos (2003), United States v. Gomez-Leon (2008)
1 federal appellate · 41 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 Ex Parte Harper · 585 So. 2d 261 - Inmon v. State
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 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"(a) Whoever shall unlawfully and unintentionally cause the death of another person while engaged in the violation of any state law or municipal ordinance applying to the operation or use of a vehicle, or vessel, as defined in Section 33-5-3, or to the regulation of traffic or boating, shall be guilty of homicide when the violation is the proximate cause of the death."”
5 later decisions quote this exact passagee.g. Sullens v. State · Danner v. State“"`We conclude that the trial court's initial reservations about tying the requisite mental state to the word "unlawfully" were sound. We endorse the "Use Note on Mens Rea Element" that accompanies the Alabama pattern jury instruction applicable to § 32-5A-192; that note states that "unintentional" is not defined in the Code but that the committee drafting the instruction assumes that word to refer to all forms of mens rea except that described by the word "intentional." The Use Note then refers to the previously referenced defined terms governing mens rea elements "intentionally," "knowingly," "recklessly," and "criminal negligence."11 Then, the Use Note correctly concludes: "`"The judge should insert the appropriate mens rea element considering the indictment and the evidence before the court. `There are few, if any, strict liability offenses in this Criminal Code....' Ala.Code § 13A-2-3 Commentary. See also § 13A-2-4(b)." "` Alabama Pattern Jury Instructions: Criminal, 14-4 to 14-6 (3d ed.1994). "`11Because § 32-5A-192(b) uses the word "unintentionally," § 13A-2-2(1), defining "intentionally," has no field of application.'”
3 later decisions quote this exact passage“Edwards's indictment did not describe a necessary culpable mental state, and the court refused her request for an instruction on a culpable mental state.”
1 later decision quote this exact passagee.g. Sullens v. State
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.