93 Wash. 2d 751 - State v. Tongate’s Empirical Analysis
1980
Citation profile
61 state decisions
How this case has been cited
Cited by 61 later decisions — most recently February 2017 · most notably 105 Wash. 2d 175 - State v. Ammons (2005), 99 Wash. 2d 413 - State v. Vladovic (1983)
61 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 In the Matter of Samuel Winship · Sandstrom v. Montana · Mullaney v. Wilbur · People v. Reese · 5 Wash. 2d 1 - State v. Furth
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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Special Verdict Form A: Was the defendant, Gary L. Eker, or an accomplice, armed with a deadly weapon at the time of the commission of the crime in Count I?[ 4 ] Answer: No (Yes or No) (Italics ours.) Special Verdict Form B: Was the defendant, Gary L. Eker, or an accomplice, armed with or in possession of a firearm at the time of the commission of the crime in Count I? Answer: Yes (Yes or No)”
2 later decisions quote this exact passage““The special verdict is a separate finding made after the guilt-determining stage of the jury’s deliberations. It cannot be assumed that a reasonable jury, in the absence of an explicit instruction on the standard of proof, will understand the applicable standard to be applied to the separate finding[.]””
2 later decisions quote this exact passage“The genius of our criminal law is violated when punishment is enhanced in the face of a reasonable doubt as to the facts leading to enhancement.”
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.