State v. Clark’s Empirical Analysis
1989
Citation profile
7 federal appellate · 118 state decisions
How this case has been cited
Cited by 129 later decisions (2 by the Supreme Court) — most recently June 2020 · most notably State v. Cunningham (2000), State v. Varela (1999)
7 federal appellate · 118 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 Strickland v. Washington · Gregg v. Georgia · Griffin v. California · Lockett v. Ohio · Griffith v. Kentucky
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 129 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he jury is instructed that even if aggravating circumstances outweigh mitigating circumstances the jury is free to not impose the penalty of death. The jury is directed to consider both the defendant and the crime. We have recognized that a subjective standard must be used for this review. These instructions adequately focus[] the jury's attention on the particularized nature of the crime and the unique characteristics of the individual defendant, as required by the Constitution.”
2 later decisions quote this exact passagee.g. State v. Fry · State v. Fry“(1) the evidence does not support the finding of a statutory aggravating circumstance; (2) the evidence supports a finding that the mitigating circumstances outweigh the aggravating circumstances; (3) the sentence of death was imposed under the influence of passion, prejudice or any other arbitrary factor; or (4) the sentence of death is excessive or disproportionate to the penalty imposed in similar cases, considering both the crime and the defendant.”
2 later decisions quote this exact passage · from the concurrencee.g. State v. Jacobs · Fry v. Lopez“[t]he doctrine of fundamental error should be applied sparingly, to prevent a miscarriage of justice, and not to excuse the failure to make proper objections in the court below. With regard to a criminal conviction, the doctrine is resorted to only if the defendant's innocence appears indisputable or if the question of his [or her] guilt is so doubtful that it would shock the conscience to permit the conviction to stand.”
2 later decisions quote this exact passagee.g. State v. Balderama · State v. Reyes
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.