State v. Williams’s Empirical Analysis

Citation profile

37 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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “By convicting the defendant of first degree murder the jury determined that the proof was sufficient to establish all the elements of that offense beyond a reasonable doubt including that the killing was “intentional, deliberate and premeditated.” In other words, by finding the defendant guilty of the highest offense to the exclusion of the immediately lesser offense, second degree murder, the jury necessarily rejected all other lesser offenses, including voluntary manslaughter. Accordingly, the trial court’s erroneous failure to charge voluntary manslaughter is harmless beyond a reasonable doubt because the jury’s verdict of guilt on the greater offense of first degree murder and its disinclination to consider the lesser included offense of second degree murder clearly demonstrates that it certainly would not have returned a verdict on voluntary manslaughter.”

   2 later decisions quote this exact passage
   e.g. State v. Wilson · State v. Halake

2. “The error in failing to charge voluntary manslaughter [in Williams ] was deemed harmless beyond a reasonable doubt because by rejecting the lesser offense of second-degree murder, the jury clearly demonstrated its disinclination to convict on any lesser offenses, including voluntary manslaughter. In contrast, the jury in this case was given no option to convict of a lesser offense.... Although the evidence clearly was sufficient to support a conviction for [lesser-included offenses], the decision to convict on those offenses was taken away from the jury. Under these circumstances, we cannot say the error was harmless beyond a reasonable doubt.”

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

3. “A final judgment ... shall not be set aside unless, considering the whole record, error involving a substantial right more probably than not affected the judgment or would result in prejudice to the judicial process.”

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