State v. Patton’s Empirical Analysis

Citation profile

2 federal appellate · 16 state decisions

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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(a) It is unlawful for any person,' knowing that an investigation or official proceeding is pending or in progress, to: (1) Alter, destroy, or conceal any record, document or thing with intent to impair its verity, legibility, or availability as evidence in the investigation or official proceeding. ...”

   2 later decisions quote this exact passage
   e.g. State of Tennessee v. Ledarren S. Hawkins · State v. Logan

2. “The defendant’s act of tossing the small bag of cocaine away from his person while in the presence of the arresting officers at the scene of the purchase does not rise to the level of conduct which constitutes a concealment ... of something for the purpose of impairing its availability for the criminal trial.... Mr. Boice merely abandoned the evidence. The statute must be construed most favorably to the accused.... [W]e do not believe that the legislature intended the simple act of abandoning a bag of crack cocaine at the scene of an arrest, in the clear sight of a law enforcement officer, to constitute the commission of this additional third-degree felony. If the defendant’s act in this case constituted tampering, then a nineteen-year-old who threw a can of beer from his car when stopped by a police officer would commit not only the second-degree misdemeanor of possession of alcoholic beverages, but also the third-degree felony of tampering with evidence. We do not believe that the legislature intended an additional felony under such circumstances.”

   1 later decision quote this exact passage
   e.g. State of Tennessee v. Ledarren S. Hawkins

3. “Like the Florida District Court of Appeal, we do not believe that the legislature intended to inflict greater punishment upon an individual for attempting to discard evidence [of a crime] than he would receive for commission of the crime. Statutes must not be construed in a manner which may lead to absurd results. [Citations omitted] If “mere abandonment” of contraband falls within the class of [conduct] made criminal by [the Tennessee evidence-tampering statute], there is a substantial likelihood of an unreasonable result. Thus, ... [e]ven if the factual allegations within the indictment are accurate, the defendant, in our view, has not violated the [evidence-tampering] statute.”

   1 later decision quote this exact passage
   e.g. Vigue v. State