Blockburger test (Rhode Island) · Go Syfert
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Blockburger test in Rhode Island

17 Rhode Island opinions name it 2 courts 1980–2013 0 in the last five years

The cases below were cited by Rhode Island courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
Blockburger v. United Statesgreen
scotus · 1931 · cited in 5 Rhode Island opinions naming this issue, 1981–2009
2 sentences

2003The Blockburger test compares the elements of the offenses to see whether "each provision requires proof of a fact which the other does not." Id. at 304.

2003The Blockburger test compares the elements of the offenses to see whether "each provision requires proof of a fact which the other does not." Id. at 304.

25
State v. Davisgreen
ri · 1978 · cited in 4 Rhode Island opinions naming this issue, 1982–2009
2 sentences

2009See State v. Davis, 120 R.I. 82, 86 , 384 A.2d 1061, 1064 (1978) (acknowledging adoption of Blockburger test).

2009See State v. Davis, 120 R.I. 82, 86 , 384 A.2d 1061, 1064 (1978) (acknowledging adoption of Blockburger test).

14
State v. Bolarinhogreen
ri · 2004 · cited in 2 Rhode Island opinions naming this issue, 2009–2010
2 sentences

2010In Bolarinho, 850 A.2d at 910-11 , we held that the counts had merged for double jeopardy purposes under the Blockburger analysis.

2010In Bolarinho, 850 A.2d at 910-11 , we held that the counts had merged for double jeopardy purposes under the Blockburger analysis.

12
Missouri v. Huntergreen
scotus · 1983 · cited in 2 Rhode Island opinions naming this issue, 1983–2003
2 sentences

2003Id. “[T]he Blockburger test is a 'rule of statutory construction,' and because it serves as a means of discerning [legislative] purpose the rule should not be controlling where, for example, there is a clear indication of contrary legislative intent.” Id. at 367 , 103 S.Ct. at 679 , 74 L.Ed.2d at 543 (quoting Albernaz v. United States, 450 U.S. 333, 340 , 101 S.Ct. 1137, 1143 , 67 L.Ed.2d 275, 282 (1981)).

2003Id. “[T]he Blockburger test is a 'rule of statutory construction,' and because it serves as a means of discerning [legislative] purpose the rule should not be controlling where, for example, there is a clear indication of contrary legislative intent.” Id. at 367 , 103 S.Ct. at 679 , 74 L.Ed.2d at 543 (quoting Albernaz v. United States, 450 U.S. 333, 340 , 101 S.Ct. 1137, 1143 , 67 L.Ed.2d 275, 282 (1981)).

12
State v. Marsichgreen
ri · 2010 · cited in 1 Rhode Island opinions naming this issue, 2013–2013
2 sentences

2013Although we agree with the trial justice’s denial of the Rule 29 motion, we arrive at our conclusion after treading a different path. 1 Standard of Review An alleged violation of the Double Jeopardy Clause is, “ ‘a mixed question of *795 law and fact of constitutional dimension!,]’ and therefore our review of such a claim is de novo.” State v. Marsich, 10 A.3d 435, 441 (R.I.2010) (quoting State v. Stone, 924 A.2d 773, 778 (R.I.2007)).

2013Although we agree with the trial justice’s denial of the Rule 29 motion, we arrive at our conclusion after treading a different path. 1 Standard of Review An alleged violation of the Double Jeopardy Clause is, “ ‘a mixed question of *795 law and fact of constitutional dimension!,]’ and therefore our review of such a claim is de novo.” State v. Marsich, 10 A.3d 435, 441 (R.I.2010) (quoting State v. Stone, 924 A.2d 773, 778 (R.I.2007)).

11
State v. Stonegreen
ri · 2007 · cited in 1 Rhode Island opinions naming this issue, 2013–2013
2 sentences

2013Although we agree with the trial justice’s denial of the Rule 29 motion, we arrive at our conclusion after treading a different path. 1 Standard of Review An alleged violation of the Double Jeopardy Clause is, “ ‘a mixed question of *795 law and fact of constitutional dimension!,]’ and therefore our review of such a claim is de novo.” State v. Marsich, 10 A.3d 435, 441 (R.I.2010) (quoting State v. Stone, 924 A.2d 773, 778 (R.I.2007)).

2013Although we agree with the trial justice’s denial of the Rule 29 motion, we arrive at our conclusion after treading a different path. 1 Standard of Review An alleged violation of the Double Jeopardy Clause is, “ ‘a mixed question of *795 law and fact of constitutional dimension!,]’ and therefore our review of such a claim is de novo.” State v. Marsich, 10 A.3d 435, 441 (R.I.2010) (quoting State v. Stone, 924 A.2d 773, 778 (R.I.2007)).

11
State v. Merciergreen
ri · 1980 · cited in 1 Rhode Island opinions naming this issue, 2004–2004
2 sentences

2004Each count in the information alleged a violation of § 11-5-2, “Felony Assault.” Section 11-5-2, formerly entitled “Assault or Battery with a Dangerous Weapon or Substance,” provided that “every person who shall make an assault or battery, or both, with a dangerous weapon, or with acid or other dangerous substance, * * * shall be punished * * *.” In 1981, the statute was amended by the General Assembly. 3 The offense was renamed “Felony Assault” and provides: “Felony Assault. — (a) Every person who shall make an assault or battery, or both, with a dangerous weapon, or with acid or other danger

2004Each count in the information alleged a violation of § 11-5-2, “Felony Assault.” Section 11-5-2, formerly entitled “Assault or Battery with a Dangerous Weapon or Substance,” provided that “every person who shall make an assault or battery, or both, with a dangerous weapon, or with acid or other dangerous substance, * * * shall be punished * * *.” In 1981, the statute was amended by the General Assembly. 3 The offense was renamed “Felony Assault” and provides: “Felony Assault. — (a) Every person who shall make an assault or battery, or both, with a dangerous weapon, or with acid or other danger

11
State v. Rodriquezgreen
ri · 1999 · cited in 1 Rhode Island opinions naming this issue, 2004–2004
1 sentence

2004See Rodriquez, 731 A.2d at 729 (relying on statute to define elements of compounding a felony for purposes of applying Blockburger test).

11
Raymond Pandelli v. United Statesgreen
ca6 · 1980 · cited in 1 Rhode Island opinions naming this issue, 2003–2003
2 sentences

2003See Pandelli v. United States, 635 F.2d 533 (6th Cir. 1980).

2003See Pandelli v. United States, 635 F.2d 533 (6th Cir. 1980).

11
State v. Ashnessgreen
ri · 1983 · cited in 1 Rhode Island opinions naming this issue, 2003–2003
2 sentences

2003Ashness, 461 A.2d at 667 n. 11.

2003Ashness, 461 A.2d at 667 n. 11.

11
Albernaz v. United Statesgreen
scotus · 1981 · cited in 1 Rhode Island opinions naming this issue, 2003–2003
2 sentences

2003Id. “[T]he Blockburger test is a 'rule of statutory construction,' and because it serves as a means of discerning [legislative] purpose the rule should not be controlling where, for example, there is a clear indication of contrary legislative intent.” Id. at 367 , 103 S.Ct. at 679 , 74 L.Ed.2d at 543 (quoting Albernaz v. United States, 450 U.S. 333, 340 , 101 S.Ct. 1137, 1143 , 67 L.Ed.2d 275, 282 (1981)).

2003Id. “[T]he Blockburger test is a 'rule of statutory construction,' and because it serves as a means of discerning [legislative] purpose the rule should not be controlling where, for example, there is a clear indication of contrary legislative intent.” Id. at 367 , 103 S.Ct. at 679 , 74 L.Ed.2d at 543 (quoting Albernaz v. United States, 450 U.S. 333, 340 , 101 S.Ct. 1137, 1143 , 67 L.Ed.2d 275, 282 (1981)).

11
State v. Grabowskigreen
ri · 1994 · cited in 1 Rhode Island opinions naming this issue, 2002–2002
2 sentences

2002See, e.g., State v. Grabowski, 644 A.2d 1282, 1286 (R.I.1994) (holding that, under Blockburger, second-degree murder is a lesser-ineluded offense of first-degree murder) (citing Blockburger v. United States, 284 U.S. 299, 804 , 52 S.Ct. 180, 182 , 76 L.Ed. 806 , 309 (1932)).

2002See, e.g., State v. Grabowski, 644 A.2d 1282, 1286 (R.I.1994) (holding that, under Blockburger, second-degree murder is a lesser-ineluded offense of first-degree murder) (citing Blockburger v. United States, 284 U.S. 299, 804 , 52 S.Ct. 180, 182 , 76 L.Ed. 806 , 309 (1932)).

11
State Ex Rel. Scott v. Berberiangreen
ri · 1971 · cited in 1 Rhode Island opinions naming this issue, 1994–1994
2 sentences

1994Scott v. Berberian, 109 R.I. 309, 316 , 284 A.2d 590, 594-95 (1971) (adopting the Blockburger test).

1994Scott v. Berberian, 109 R.I. 309, 316 , 284 A.2d 590, 594-95 (1971) (adopting the Blockburger test).

11
State v. Burgessgreen
ri · 1983 · cited in 1 Rhode Island opinions naming this issue, 1989–1989
2 sentences

1989In State v. Burgess, 465 A.2d 204, 205 (R.I.1983), we acknowledged the state’s concession that this court “should vacate the conviction of committing an abominable and detestable crime against nature because this conviction and the first-degree sexual-assault conviction result from the same forcible-fellatio offense, thereby violating the double-jeopardy clause.” Having previously decided the precise point of law raised by defendant in a manner favorable to him, we must next determine whether there is any substance in fact to his argument.

1989In State v. Burgess, 465 A.2d 204, 205 (R.I.1983), we acknowledged the state’s concession that this court “should vacate the conviction of committing an abominable and detestable crime against nature because this conviction and the first-degree sexual-assault conviction result from the same forcible-fellatio offense, thereby violating the double-jeopardy clause.” Having previously decided the precise point of law raised by defendant in a manner favorable to him, we must next determine whether there is any substance in fact to his argument.

11
State v. Boudreaugreen
ri · 1974 · cited in 1 Rhode Island opinions naming this issue, 1981–1981
2 sentences

1981See State v. Boudreau, 113 R.I. 497 , 322 A.2d 626 (1974); State ex rel.

1981See State v. Boudreau, 113 R.I. 497 , 322 A.2d 626 (1974); State ex rel.

11
Thomas v. Stategreen
md · 1976 · cited in 1 Rhode Island opinions naming this issue, 1980–1980
2 sentences

1980We also note with approval the lucid application of the Blockburger test by the Maryland Court of Appeals in Thomas v. State, 277 Md. 257, 267 , 353 A.2d 240, 246-47 (1976): “The required evidence is that which is minimally necessary to secure a conviction for each statutory offense.

1980We also note with approval the lucid application of the Blockburger test by the Maryland Court of Appeals in Thomas v. State, 277 Md. 257, 267 , 353 A.2d 240, 246-47 (1976): “The required evidence is that which is minimally necessary to secure a conviction for each statutory offense.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Rhode Island. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Iannelli v. United States green
scotus · 1975
2 sentences

1982In State v. Davis, R.I., 384 A.2d at 1064 , we further explained how the Blockburger test is to be applied: “The test centers on the elements of the two crimes with the goal of ascertaining whether each crime charged, notwithstanding a possible factual overlap, requires proof of an element that the other *1386 does not Iannelli v. United States, 420 U.S. 770 , 785 n.17, 95 S.Ct. 1284 , 1293-94 n. 17, 43 L.Ed.2d 616 , 627 n.17 (1975).

1982In State v. Davis, R.I., 384 A.2d at 1064 , we further explained how the Blockburger test is to be applied: “The test centers on the elements of the two crimes with the goal of ascertaining whether each crime charged, notwithstanding a possible factual overlap, requires proof of an element that the other *1386 does not Iannelli v. United States, 420 U.S. 770 , 785 n.17, 95 S.Ct. 1284 , 1293-94 n. 17, 43 L.Ed.2d 616 , 627 n.17 (1975).

21982–1996
State v. Rodriguez green
ri · 2003
2 sentences

2004The analytical test has been most recently set out in State v. Rodriquez , 822 A.2d at 905 -06 .

2004The analytical test has been most recently set out in State v. Rodriquez , 822 A.2d at 905 -06 .

12004–2004

Statutes the citing opinions construe

RI § R.I. Gen. Laws § 11-5-2 (5) RI § R.I. Gen. Laws § 11-23-1 (4) RI § R.I. Gen. Laws § 11-1-6 (3) RI § R.I. Gen. Laws § 11-39-1 (3) RI § R.I. Gen. Laws § 11-47-2 (3) RI § R.I. Gen. Laws § 11-47-3 (3) RI § R.I. Gen. Laws § 11-47-8 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 409 (1982–2026) FL 171 (1981–2026) NM 151 (1991–2026) LA 139 (1980–2025) WA 133 (1982–2026) TN 130 (1977–2026) OH 105 (1980–2026) CT 96 (1985–2026) VA 89 (1979–2026) MI 88 (1978–2026) AL 71 (1977–2025) KY 66 (1984–2026) IN 65 (1978–2020) MD 61 (1962–2022) DC 57 (1981–2026) MO 57 (1977–2024) MS 54 (1981–2023) PA 53 (1982–2025) IL 48 (1977–2023) WI 37 (1979–2023) ID 34 (1980–2025) WV 32 (1983–2025) MT 32 (1981–2024) WY 30 (1987–2023) NC 26 (1981–2026) NJ 25 (1982–2019) CO 23 (1980–2017) DE 22 (1980–2025) IA 22 (1983–2026) SC 21 (1990–2021) NV 20 (1984–2024) NY 20 (1978–2019) AZ 19 (1981–2024) SD 19 (1988–2019) RI 17 (1980–2013) NE 16 (1991–2025) VT 16 (1998–2024) GA 14 (1979–2023) AR 14 (1993–2024) ME 14 (1992–2025) OK 11 (1981–2024) HI 9 (1991–2005) MN 9 (1979–2013) OR 8 (1982–2020) CA 7 (2001–2020) MA 7 (1981–2023) VI 7 (1997–2013) KS 6 (1989–2006) AK 4 (1995–2024) ND 4 (2006–2023) GU 2 (2023–2025) NH 2 (1984–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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