Vigue v. State’s Empirical Analysis
1999
Citation profile
20 state decisions
How this case has been cited
Cited by 21 later decisions — most recently February 2021
20 state decisions — followed in 11 states
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 429 Pa. Super. 464 - Commonwealth v. Govens · State v. James · 314 N.J. Super. 440 - State v. Sharpless · State v. Fuqua · 666 So. 2d 131 - Simmons 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]t is important not to confuse [the defendant’s] intent with his physical actions. The evidence-tampering statute uses the terms “suppress” and “conceal” to define the actus reus of the crime. In addition to this actus reus, the statute also requires proof of a culpable mental state — here, [the defendant’s] intent to “impair [the] availability” of the evidence. The fact that [the defendant] intended to make it harder for Officer Kantor to detect the cocaine does not mean that [the defendant] actually succeeded in ... “concealing” the cocaine when he tossed or dropped it to the ground. Indeed, under the facts of this case, no suppression or concealment occurred .... 12”
3 later decisions quote this exact passage“One could argue that, even if Vigue did not succeed in suppressing or concealing the cocaine, he nevertheless tried to do so, and so his conviction should be reduced to attempted evidence-tampering. Again, this would make sense if we interpreted the terms "suppress" and "conceal" broadly. But ... we are persuaded to give a narrow interpretation to the terms "suppress" and "conceal." We are convinced that a broad reading of these terms would lead to results that are inexplicably harsh and probably not within the legislature's intent.... As [other state courts noted], if the words "suppress" and "conceal" are interpreted to cover actions such as tossing evidence to the ground, or tossing evidence out of a car window, or hiding evidence in one's clothing, then minor possessory offenses would often be converted to felonies with little reason.”
2 later decisions quote this exact passage“holding that a broad reading of these terms”
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.