State v. Brake’s Empirical Analysis
1921
Citation profile
2 federal appellate · 31 state decisions
How this case has been cited
Cited by 35 later decisions — most recently May 2019 · most notably State v. Leland (1951), State v. Folkes (1944)
2 federal appellate · 31 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 Spicer v. State · People v. Glaze · People v. . Becker · State v. Steeves · People v. . Becker
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“" 'A conviction cannot be had upon the testimony of an accomplice, unless he be corroborated by such other evidence as tends to connect the defendant with the commission of the crime, and the corroboration is not sufficient if it merely show the commission of the crime, or the circumstances of the commission.' "”
3 later decisions quote this exact passagee.g. State v. Riley · State v. Young““The statute uses precise language. It is not necessary that there shall be corroborating evidence concerning every material fact as to which the accomplice testified, and it is not necessary that the whole case shall be proved outside the testimony of the accomplice ; for, if the statute contained such a requirement, accomplice testimony could never avail anything except as cumulative evidence. Our statute in plain words permits a conviction ‘upon the testimony of an accomplice’; with the limitation, however, upon such permission, that the accomplice shall be corroborated ‘by such other evidence as tends to connect’ the defendant with the commission of the crime. The language of the statute is ‘other evidence’; and, hence, the corroborative evidence must be independent of the testimony of the accomplice. The corroborating evidence must connect, or tend to connect, the defendant with the commission of the crime charged; and, furthermore, the tendency of the corroborative evidence to connect the defendant must be independent of any testimony of the accomplice. The corroborative evidence must of its own force, independently of the accomplice testimony, tend to connect the defendant with the commission of the crime. ’ ’ (Italics supplied.)”
2 later decisions quote this exact passage“"[L]ike the statutes in many other states, [Oregon's accomplice statute] is in effect a legislative declaration that it is dangerous to permit convictions upon the uncorroborated testimony of the accomplice ***."”
1 later decision quote this exact passagee.g. State v. Riley
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.