Block-burger test (District of Columbia) · Go Syfert
← District of Columbia issues

Block-burger test in District of Columbia

10 District of Columbia opinions name it 1 courts 1981–2008 0 in the last five years

The cases below were cited by District of Columbia 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 (7)

CaseFollowedCited
Whalen v. United Statesgreen
scotus · 1980 · cited in 2 District of Columbia opinions naming this issue, 1981–2005
2 sentences

2005“In [this] jurisdiction, the Block-burger rule ... has been codified as an express declaration of legislative intent in D.C.Code § 23-112 [(2002).]” 6 Byrd v. United States, 598 A.2d 386, 389 (D.C.1991) (en banc) (citing Whalen v. United States, 445 U.S. 684, 691-92 , 100 S.Ct. 1432 , 63 L.Ed.2d 715 (1980)).

2005“In [this] jurisdiction, the Block-burger rule ... has been codified as an express declaration of legislative intent in D.C.Code § 23-112 [(2002).]” 6 Byrd v. United States, 598 A.2d 386, 389 (D.C.1991) (en banc) (citing Whalen v. United States, 445 U.S. 684, 691-92 , 100 S.Ct. 1432 , 63 L.Ed.2d 715 (1980)).

12
Hanna v. United Statesgreen
dc · 1995 · cited in 1 District of Columbia opinions naming this issue, 2008–2008
2 sentences

2008See Hanna, 666 A.2d at 857 (PFCV requires possession of a firearm during a crime of violence while PPW requires possession of a “specifically prohibited weapon For all the foregoing reasons, appellant’s convictions are hereby Affirmed. 3 .

2008See Hanna, 666 A.2d at 857 (PFCV requires possession of a firearm during a crime of violence while PPW requires possession of a “specifically prohibited weapon For all the foregoing reasons, appellant’s convictions are hereby Affirmed. 3 .

11
Byrd v. United Statesgreen
dc · 1991 · cited in 1 District of Columbia opinions naming this issue, 2005–2005
2 sentences

2005“In [this] jurisdiction, the Block-burger rule ... has been codified as an express declaration of legislative intent in D.C.Code § 23-112 [(2002).]” 6 Byrd v. United States, 598 A.2d 386, 389 (D.C.1991) (en banc) (citing Whalen v. United States, 445 U.S. 684, 691-92 , 100 S.Ct. 1432 , 63 L.Ed.2d 715 (1980)).

2005“In [this] jurisdiction, the Block-burger rule ... has been codified as an express declaration of legislative intent in D.C.Code § 23-112 [(2002).]” 6 Byrd v. United States, 598 A.2d 386, 389 (D.C.1991) (en banc) (citing Whalen v. United States, 445 U.S. 684, 691-92 , 100 S.Ct. 1432 , 63 L.Ed.2d 715 (1980)).

11
Joiner v. United Statesgreen
dc · 1991 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
2 sentences

1993See Joiner v. United States, 585 A.2d 176 , 179 & n. 2 (D.C.1991); see also Briscoe v. United States, 528 A.2d 1243, 1245 (D.C.1987) (Blockburger inapplicable to merger of two violations of same statute); Bean, supra, 576 A.2d at 189 n. 3.

1993See Joiner v. United States, 585 A.2d 176 , 179 & n. 2 (D.C.1991); see also Briscoe v. United States, 528 A.2d 1243, 1245 (D.C.1987) (Blockburger inapplicable to merger of two violations of same statute); Bean, supra, 576 A.2d at 189 n. 3.

11
Ray v. United Statesgreen
dc · 1993 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
2 sentences

1993Ray v. United States, 620 A.2d 860, 864 (D.C.1993).

1993Ray v. United States, 620 A.2d 860, 864 (D.C.1993).

11
Briscoe v. United Statesgreen
dc · 1987 · cited in 1 District of Columbia opinions naming this issue, 1993–1993
2 sentences

1993See Joiner v. United States, 585 A.2d 176 , 179 & n. 2 (D.C.1991); see also Briscoe v. United States, 528 A.2d 1243, 1245 (D.C.1987) (Blockburger inapplicable to merger of two violations of same statute); Bean, supra, 576 A.2d at 189 n. 3.

1993See Joiner v. United States, 585 A.2d 176 , 179 & n. 2 (D.C.1991); see also Briscoe v. United States, 528 A.2d 1243, 1245 (D.C.1987) (Blockburger inapplicable to merger of two violations of same statute); Bean, supra, 576 A.2d at 189 n. 3.

11
Albernaz v. United Statesgreen
scotus · 1981 · cited in 1 District of Columbia opinions naming this issue, 1981–1981
1 sentence

1981Moreover the Supreme Court has recognized that “[t]he Blockburger test is a ‘rule of statutory construction’ and because it serves as a means of discerning congressional purpose the rule should not be controlling where, for example, there is a clear indication of contrary legislative intent.” Albernaz v. United States, supra - U.S. at -, 101 S.Ct. at 1141 (Block-burger test applied because nothing in legislative history discloses contrary intent).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Nixon v. United States green
dc · 1999
2 sentences

2006Nixon, 730 A.2d at 152 .

2006Nixon, 730 A.2d at 152 .

12006–2006
United States v. Dalton green
cod · 1992
1 sentence

1996Id. at 354-55 .

11996–1996
Bean v. United States green
dc · 1990
2 sentences

1993See Joiner v. United States, 585 A.2d 176 , 179 & n. 2 (D.C.1991); see also Briscoe v. United States, 528 A.2d 1243, 1245 (D.C.1987) (Blockburger inapplicable to merger of two violations of same statute); Bean, supra, 576 A.2d at 189 n. 3.

1993See Joiner v. United States, 585 A.2d 176 , 179 & n. 2 (D.C.1991); see also Briscoe v. United States, 528 A.2d 1243, 1245 (D.C.1987) (Blockburger inapplicable to merger of two violations of same statute); Bean, supra, 576 A.2d at 189 n. 3.

11993–1993
Blockburger v. United States green
scotus · 1931
2 sentences

1991Absent clear legislative intent, in situations “where the same act or transaction constitutes a violation of two distinct statutory provisions, the test to be applied to determine whether there are two offenses or only one, is whether each provision requires proof of a fact which the other does not.” Blockburger v. United States, 284 U.S. 299, 304 , 52 S.Ct. 180, 182 , 76 L.Ed. 306 (1932). 2 If only one of the statutes *1374 requires an additional element, the Block-burger test is not satisfied and the offenses merge.

1991Absent clear legislative intent, in situations “where the same act or transaction constitutes a violation of two distinct statutory provisions, the test to be applied to determine whether there are two offenses or only one, is whether each provision requires proof of a fact which the other does not.” Blockburger v. United States, 284 U.S. 299, 304 , 52 S.Ct. 180, 182 , 76 L.Ed. 306 (1932). 2 If only one of the statutes *1374 requires an additional element, the Block-burger test is not satisfied and the offenses merge.

11991–1991
Iannelli v. United States green
scotus · 1975
2 sentences

1987Brown v. Ohio, 432 U.S. 161, 166 , 97 S.Ct. 2221, 2225-26 , 53 L.Ed.2d 187 (1977) (citing Iannelli v. United States, 420 U.S. 770 , 785 n. 17, 95 S.Ct. 1284 , 1293-94 n. 17, 43 L.Ed.2d 616 (1975)).

1987Brown v. Ohio, 432 U.S. 161, 166 , 97 S.Ct. 2221, 2225-26 , 53 L.Ed.2d 187 (1977) (citing Iannelli v. United States, 420 U.S. 770 , 785 n. 17, 95 S.Ct. 1284 , 1293-94 n. 17, 43 L.Ed.2d 616 (1975)).

11987–1987
Brown v. Ohio green
scotus · 1977
2 sentences

1987Brown v. Ohio, 432 U.S. 161, 166 , 97 S.Ct. 2221, 2225-26 , 53 L.Ed.2d 187 (1977) (citing Iannelli v. United States, 420 U.S. 770 , 785 n. 17, 95 S.Ct. 1284 , 1293-94 n. 17, 43 L.Ed.2d 616 (1975)).

1987Brown v. Ohio, 432 U.S. 161, 166 , 97 S.Ct. 2221, 2225-26 , 53 L.Ed.2d 187 (1977) (citing Iannelli v. United States, 420 U.S. 770 , 785 n. 17, 95 S.Ct. 1284 , 1293-94 n. 17, 43 L.Ed.2d 616 (1975)).

11987–1987
Ball v. United States green
scotus · 1985
2 sentences

1986Congress could not have intended to allow two convictions for the same conduct, even if sentenced under only one; Congress does not create criminal offenses having no sentencing component. 105 S.Ct. at 1672 .

1986Congress could not have intended to allow two convictions for the same conduct, even if sentenced under only one; Congress does not create criminal offenses having no sentencing component. 105 S.Ct. at 1672 .

11986–1986

Statutes the citing opinions construe

DC § D.C. Code § 23-112 (7) DC § D.C. Code § 22-401 (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 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.

← Caselaw search · G Cite Topics · Brief Check