Leos v. State’s Empirical Analysis
1994
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently August 2014
14 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 Jackson v. Virginia · Moreno v. State · Hai Hai Vuong v. State · Turro v. State · Whiting 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The very language of Section 38.03 indicates that the required force must be directed at the officer or applied to him. Appellant appropriately points to the Practice Commentary to Section 38.03: One who runs away or makes an effort to shake off the officer’s detaining grip may be guilty of evading arrest under Section 38.04, but he is not responsible under this section. The Practice Commentary has been cited by the Court of Criminal Appeals with apparent approval. [[Image here]] Striking an arresting officer’s arm away constitutes force directed against the officer. This is distinctly different from the direction of force employed in simply pulling one’s arm away. There, is no danger of injury to the officer in the latter action. .”
1 later decision quote this exact passagee.g. Bryant v. State“The idea of violence directed specifically toward Officer Landrum conflicts with this image of appellant crawling on his shoulders and knees with his hands clasped to his stomach. By attempting to crawl away, appellant invited prosecution for evading arrest. Merely trying to flee does not, however, involve sufficient force directed at the peace officer to sustain a conviction for resisting arrest. Nor is the peace officer the object of any force expended in shaking off a detaining grip, which implies no less force than refusing to submit to the handcuffs.”
1 later decision quote this exact passagee.g. Bryant 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.