83 Wash. App. 803 - State v. Frohs’s Empirical Analysis
1996
Citation profile
40 state decisions
How this case has been cited
Cited by 42 later decisions — most recently January 2023 · most notably 135 Wash. 2d 326 - State v. Riles (1998), 153 Wash. 2d 765 - State v. Freeman (2005)
40 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 · Brown v. Ohio · Whalen v. United States · Albernaz v. United States · Ball v. United States
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the location of the offenses within the statutory scheme, the injuries the offenses prohibit, and the presence of language clearly requiring that the State, to prove one crime, prove `not only that a defendant committed that crime ... but that the crime was accompanied by an act which is defined as a crime elsewhere in the criminal statutes....'”
3 later decisions quote this exact passage“[a]n additional conviction for the `included' [1] crime cannot be allowed to stand unless it involves some injury to the person or property of the victim or others, which is separate and distinct from and not merely incidental to the crime of which it forms an element.”
3 later decisions quote this exact passage“[T]he merger doctrine is a rule of statutory construction which only applies where the Legislature has clearly indicated that in order to prove a particular degree of crime ( e.g., first degree rape) the State must prove not only that a defendant committed that crime ( e.g., rape) but that the crime was accompanied by an act which is defined as a crime elsewhere in the criminal statutes ( e.g., assault or kidnapping)....[ [17] ]”
2 later decisions 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.