106 Wash. 2d 885 - State v. Hahn’s Empirical Analysis
1986
Citation profile
38 state decisions
How this case has been cited
Cited by 38 later decisions — most recently September 2023 · most notably 119 Wash. 2d 294 - State v. Ortiz (1992), 137 Wis. 2d 65 - Douglas County v. Edwards (1987)
38 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 Johnson v. Zerbst · Faretta v. California · Adams v. United States Ex Rel. McCann · Von Moltke v. Gillies · Westbrook v. Arizona
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“For purposes of clarification, the respective standards for waiver follow: The test for competency to stand trial is if the defendant has the capacity to understand the nature of the proceedings against him and to assist in his own defense. [State v.] Ortiz, [ 104 Wn.2d 479 ,] 482, [ 706 P.2d 1069 (1985)]; RCW 10.77.010(6). The standards for waiver of both an insanity plea and the right to counsel are (1) competency to stand trial and (2) a knowing and intelligent waiver with “eyes open”, which includes an awareness of the dangers and disadvantages of the decision. [State v.] Jones, [ 99 Wn.2d 735 ,] 741, [ 664 P.2d 1216 (1983)] (citing Faretta v. California, [ 422 U.S. 806 ]). In each case, the trial court must make a factual determination on the record.”
1 later decision quote this exact passage · from the majority“[I]t is the responsibility of the trial court to determine a defendant's competency intelligently to waive the service of counsel and act as his own counsel, ... [but] any consideration of a defendant's ability to `exercise the skill and judgment necessary to secure himself a fair trial' was rendered inappropriate by Faretta .”
1 later decision quote this exact passage · from the majoritye.g. State v. Vermillion“[w]hether there has been an intelligent waiver of counsel is an ad hoc determination which depends upon the particular facts and circumstances of the case, including the background, experience and conduct of the accused.”
1 later decision quote this exact passage · from the majority
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.