Block-burger test (Indiana) · Go Syfert
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Block-burger test in Indiana

11 Indiana opinions name it 2 courts 1978–2012 0 in the last five years

The cases below were cited by Indiana 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 (6)

CaseFollowedCited
Blockburger v. United Statesgreen
scotus · 1931 · cited in 3 Indiana opinions naming this issue, 1978–2012
2 sentences

1989Blockburger v. United States (1932), 284 U.S. 299 , 52 S.Ct. 180 , 76 L.Ed. 306 , cited in Missouri v. Hunter, supra. The Block-burger test bears repeating: “Each of the offenses created requires proof of a different element.

1989Blockburger v. United States (1932), 284 U.S. 299 , 52 S.Ct. 180 , 76 L.Ed. 306 , cited in Missouri v. Hunter, supra. The Block-burger test bears repeating: “Each of the offenses created requires proof of a different element.

13
Iannelli v. United Statesgreen
scotus · 1975 · cited in 2 Indiana opinions naming this issue, 1978–1985
2 sentences

1985The test emphasizes the elements of the offenses and so "[i]f each requires proof of *1154 a fact that the other does not, the Block-burger test is satisfied, notwithstanding a substantial overlap in the proof offered to establish the crimes...." Iannelli v. United States (1975), 420 U.S. 770, 785, n. 17 , 95 S.Ct. 1284 , 43 L.Ed.2d 616 .

1985The test emphasizes the elements of the offenses and so "[i]f each requires proof of *1154 a fact that the other does not, the Block-burger test is satisfied, notwithstanding a substantial overlap in the proof offered to establish the crimes...." Iannelli v. United States (1975), 420 U.S. 770, 785, n. 17 , 95 S.Ct. 1284 , 43 L.Ed.2d 616 .

12
McIntire v. Stategreen
ind · 1999 · cited in 1 Indiana opinions naming this issue, 2000–2000
2 sentences

2000Consistent with the absence of a federal double jeopardy violation under the Block-burger test, simultaneous convictions of robbery and confinement charges do not violate Indiana’s “analogous statutory elements test.” Smith, 717 N.E.2d at 1281 (citing Mclntire v. State, 717 N.E.2d 96, 99 (Ind.1999)).

2000Consistent with the absence of a federal double jeopardy violation under the Block-burger test, simultaneous convictions of robbery and confinement charges do not violate Indiana’s “analogous statutory elements test.” Smith, 717 N.E.2d at 1281 (citing Mclntire v. State, 717 N.E.2d 96, 99 (Ind.1999)).

11
Illinois v. Vitalegreen
scotus · 1980 · cited in 1 Indiana opinions naming this issue, 1999–1999
2 sentences

1999Illinois v. Vitale, 447 U.S. 410, 416 , 100 S.Ct. 2260, 2265 , 65 L.Ed.2d 228, 235 (1980) (citations omitted).

1999Illinois v. Vitale, 447 U.S. 410, 416 , 100 S.Ct. 2260, 2265 , 65 L.Ed.2d 228, 235 (1980) (citations omitted).

11
United States v. Dixongreen
scotus · 1993 · cited in 1 Indiana opinions naming this issue, 1997–1997
2 sentences

1997The Block burger inquiry, accordingly, serves as a means to determine this intent.” Dixon, 509 U.S. at 735 , 113 S.Ct. at 2881-82 , 125 L.Ed.2d at 593 (White, J., concurring in part and dissenting in part) (emphasis added).

1997The Block burger inquiry, accordingly, serves as a means to determine this intent.” Dixon, 509 U.S. at 735 , 113 S.Ct. at 2881-82 , 125 L.Ed.2d at 593 (White, J., concurring in part and dissenting in part) (emphasis added).

11
Scrougham v. Stategreen
indctapp · 1990 · cited in 1 Indiana opinions naming this issue, 1992–1992
2 sentences

1992See also, Scrougham v. State (1990), Ind.App., 564 N.E.2d 542 , trans. denied.

1992See also, Scrougham v. State (1990), Ind.App., 564 N.E.2d 542 , trans. denied.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
Elmore v. State green
ind · 1978
2 sentences

1992This test or standard was further developed in Brown v. Ohio (1977), 432 U.S. 161, 166 , 97 S.Ct. 2221, 2226 , 58 L.Ed.2d 187 : This test emphasizes the elements of the two crimes. 'If each requires proof of a fact that the other does not, the Block-burger test is satisfied, notwithstanding a substantial overlap in the proof offered to establish the crimes ...' [Citations omitted.] Indiana adopted the Blockburger and Brown tests in Elmore v. State (1978), 269 Ind. 522 , 382 N.E.2d 893 , 897: The focus of a proper double jeopardy analysis must be on whether or not the offenses to be prosecuted

1992This test or standard was further developed in Brown v. Ohio (1977), 432 U.S. 161, 166 , 97 S.Ct. 2221, 2226 , 58 L.Ed.2d 187 : This test emphasizes the elements of the two crimes. 'If each requires proof of a fact that the other does not, the Block-burger test is satisfied, notwithstanding a substantial overlap in the proof offered to establish the crimes ...' [Citations omitted.] Indiana adopted the Blockburger and Brown tests in Elmore v. State (1978), 269 Ind. 522 , 382 N.E.2d 893 , 897: The focus of a proper double jeopardy analysis must be on whether or not the offenses to be prosecuted

31983–1992
Brown v. Ohio green
scotus · 1977
2 sentences

1992This test or standard was further developed in Brown v. Ohio (1977), 432 U.S. 161, 166 , 97 S.Ct. 2221, 2226 , 58 L.Ed.2d 187 : This test emphasizes the elements of the two crimes. 'If each requires proof of a fact that the other does not, the Block-burger test is satisfied, notwithstanding a substantial overlap in the proof offered to establish the crimes ...' [Citations omitted.] Indiana adopted the Blockburger and Brown tests in Elmore v. State (1978), 269 Ind. 522 , 382 N.E.2d 893 , 897: The focus of a proper double jeopardy analysis must be on whether or not the offenses to be prosecuted

1992This test or standard was further developed in Brown v. Ohio (1977), 432 U.S. 161, 166 , 97 S.Ct. 2221, 2226 , 58 L.Ed.2d 187 : This test emphasizes the elements of the two crimes. 'If each requires proof of a fact that the other does not, the Block-burger test is satisfied, notwithstanding a substantial overlap in the proof offered to establish the crimes ...' [Citations omitted.] Indiana adopted the Blockburger and Brown tests in Elmore v. State (1978), 269 Ind. 522 , 382 N.E.2d 893 , 897: The focus of a proper double jeopardy analysis must be on whether or not the offenses to be prosecuted

31978–1992
Richardson v. State green
ind · 1999
2 sentences

2000Consistent with the absence of a federal double jeopardy violation under the Block-burger test, simultaneous convictions of robbery and confinement charges do not violate Indiana’s “analogous statutory elements test.” Smith, 717 N.E.2d at 1281 (citing Mclntire v. State, 717 N.E.2d 96, 99 (Ind.1999)).

2000Consistent with the absence of a federal double jeopardy violation under the Block-burger test, simultaneous convictions of robbery and confinement charges do not violate Indiana’s “analogous statutory elements test.” Smith, 717 N.E.2d at 1281 (citing Mclntire v. State, 717 N.E.2d 96, 99 (Ind.1999)).

12000–2000
United States v. Jorge Enrique Gonzalez, A/K/A George, Maurice Roundy, Michael Timothy Sweeton green
ca11 · 1991
2 sentences

1995Citing Garreft, the Eleventh Circuit has stated, "Once the primary tool for Double Jeopardy determinations, the Block-burger test is apparently now used, in large part, as a 'cannon of statutory construction'...." Gonzalez, supra, 921 F.2d at 1536 n. 5.

1995Citing Garreft, the Eleventh Circuit has stated, "Once the primary tool for Double Jeopardy determinations, the Block-burger test is apparently now used, in large part, as a 'cannon of statutory construction'...." Gonzalez, supra, 921 F.2d at 1536 n. 5.

11995–1995

Statutes the citing opinions construe

IN § Ind. Code § 35-42-5-1 (4)

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 31 (1986–2017) IN 11 (1978–2012) DC 10 (1981–2008) TN 8 (1991–2016) CT 8 (1988–1995) FL 7 (1982–2017) MI 7 (1983–2011) IA 6 (1992–2015) DE 6 (1980–2015) NM 6 (1994–2011) IL 5 (1981–1989) MD 4 (1988–1995) SD 4 (1996–2014) WA 4 (1982–1998) WI 4 (1978–2004) MO 4 (1981–1991) CO 3 (1994–2012) AZ 3 (1991–2008) WV 3 (1983–1993) SC 3 (1995–1998) KY 3 (1990–2012) PA 3 (1986–2017) LA 3 (1993–2013) MT 3 (1983–1997) MN 2 (1985–2013) MA 2 (1998–2009) OK 2 (1992–1999)

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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