107 Ohio App. 3d 646 - State v. Ziepfel’s Empirical Analysis
1995
Citation profile
25 state decisions
How this case has been cited
Cited by 25 later decisions — most recently September 2022 · most notably 134 Ohio App. 3d 395 - State v. Bybee (1999), 164 Ohio App. 3d 114 - State v. Walker (2005)
25 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 Austin v. United States · Alexander v. United States · State v. Hill · United States v. Busher · United States v. One Single Family Residence Located at 18755 North Bay Road
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[I]n personam criminal forfeitures * * *, which operate on the premise that the property being forfeited was obtained independent of any illegal activity, are subject to an excessiveness inquiry. That inquiry essentially asks whether the value of the property being forfeited is an excessive monetary punishment in relation to the offense giving rise to the forfeiture. In other words, the excessiveness inquiry turns on whether the government can exact a fine in the amount of the forfeiture in light of the defendant’s conduct and the offense committed. This inquiry beckons a comparison of the value of the property being forfeited to the gravity of the offense committed by the defendant and the nature and extent of the defendant’s activities.””
1 later decision quote this exact passage · from the concurrence“In personam forfeitures are `assessments, whether monetary or in kind, to punish the property owner's criminal conduct.' * * * They are actions against the person, not the property, a form of punishment no different from a fine.”
1 later decision quote this exact passage · from the concurrence“all the badges of a criminal in personam forfeiture subject to the Excessive Fines Clause of the Eighth Amendment.”
1 later decision quote this exact passage
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.