State v. Anthony’s Empirical Analysis
1991
Citation profile
47 state decisions
How this case has been cited
Cited by 49 later decisions — most recently August 2017 · most notably State v. Salamon (2008), State v. Denton (1996)
47 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 Blockburger v. United States · Iannelli v. United States · Bowsher v. Merck & Co. · 94 Wash. 2d 216 - State v. Green · State v. Logan
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“whether the confinement, movement, or detention is essentially incidental to the accompanying felony and is not, therefore, sufficient to support a separate conviction for kidnapping, or whether it is significant enough, in and of itself, to warrant independent prosecution and is, therefore, sufficient to support such a conviction.”
9 later decisions quote this exact passage · from the dissente.g. State v. Rolland · State v. Roberts“(a) Any person who unlawfully seizes, confines, inveigles, entices, decoys, abducts, conceals, kidnaps or carries away another with the felonious intent to: (1) Cause the other to be confined secretly against his will; (2) Detain the other against his will; or (3) Send the other out of state against his will, shall be guilty of aggravated kidnapping when one or more of the following circumstances are present: (A) The victim is a child under the age of thirteen (13) years; (B) The victim suffers serious bodily injury ... as a proximate result of the secret confinement, unlawful detention or being sent out of the state; (C) The person secretly confined, unlawfully detained or sent out of the state is the victim of any felony committed on his person during the secret confinement, unlawful detention or carrying out of the state; (D) The secret confinement, unlawful detention or carrying out of the state is accomplished while defendant is armed with a deadly weapon; (E) The secret confinement, unlawful detention or carrying out of the state is for the purpose of obtaining ransom, reward or to commit extortion from the victim or any other person; (F) The secret confinement or unlawful detention is for the purpose of holding the victim hostage or using the victim as a shield; or (G) The victim is mentally incompetent and under the age of eighteen (18) years.”
1 later decision quote this exact passage · from the dissente.g. State v. White“The defendants in both Anthony and [its companion case] were convicted of aggravated kidnapping and armed robbery. The issue with which we were confronted in Anthony was whether movements or confinements merely incidental to robbery should sustain separate kidnapping convictions. We held that a kidnapping conviction violated due process when predicated on movement or confinement that was merely incidental to an accompanying felony and not “significant enough, in and of itself, to warrant independent prosecution.” [[Image here]] The Anthony decision should only prevent the injustice which would occur if a defendant could be convicted of kidnapping where the only restraint utilized was that necessary to complete the act of rape or robbery. Accordingly, any restraint in addition to that which is necessary to consummate rape or robbery may support a separate conviction for kidnapping.”
1 later decision quote this exact passage · from the dissente.g. State v. Turner
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.