State v. Beals’s Empirical Analysis

Citation profile

12 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “A completed second degree assault is not necessary to prove attempt to commit first degree robbery, and it is unlikely the legislature intended ... the merger doctrine to so apply here. The attempted robbery was complete as soon as Beals formed the requisite intent and took the hammer in hand, and is distinguishable from Beals' act of hitting Perry on the head to complete the assault.... Similarly here, all that was required to satisfy the elements of attempted first degree robbery was a substantial step, which may or may not have included actual injury to the victim. The merger doctrine is thus inapplicable. Id. at 193-95, 997 P.2d 941 (citations omitted). Kier was convicted of completed first degree robbery, which required more than a substantial step. That the assault here involved assault with a deadly weapon, rather than by the infliction of substantial bodily harm, does not defeat application of the merger doctrine. The fact remains that the completed assault was necessary to elevate the completed robbery to first degree. See Freeman, 153 Wash.2d at 778 , 108 P.3d 753 .”

   2 later decisions quote this exact passage
   e.g. State v. Kier · In Re Francis

2. “with intent to commit a specific crime, he does any act which is a substantial step toward the commission of that crime.”

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

3. “A challenge to the classification of an out-of-state conviction is reviewed de novo.”

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