Graves v. State’s Empirical Analysis
1996
Citation profile
28 state decisions
How this case has been cited
Cited by 28 later decisions — most recently December 2021 · most notably Tanksley v. State (1997), Williams v. State (2018)
28 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 Jackson v. Virginia · Barker v. Wingo · Faretta v. California · Hoffa v. United States · National Union Fire Insurance v. Helfand
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The cold record is a poor substitute for demeanor observation.”
4 later decisions quote this exact passage“[T]he defendant's technical knowledge is not the relevant inquiry. In order for a defendant's waiver of right to counsel to withstand constitutional scrutiny, the judge need only be convinced that the defendant made his decision with a clear comprehension of the attendant risks.”
2 later decisions quote this exact passage“does not require the trial court to explain the elements of the charged offense), but once it did, that inquiry revealed that Miles did not understand the sex trafficking charge and thus 10 may not have appreciated the disadvantages of self-representation. And the inadequacy of the trial court's canvass appears again in its conclusion. Rather than specifically determining whether Miles understood the rights that he was waiving and the consequences of waiver, as SCR 253(4)(b) requires, the court simply noted that Miles answered the questions posed and indicated that he believed he could do a better job in the face of the court's efforts to dissuade him. When these errors—i.e., the trial courfs failure to address Miles expressed lack of understanding about the potential sentences and the elements of sex trafficking—are taken together, we are unable to say with any confidence that Miles' waiver of the right to counsel was knowing and voluntary. As an invalid waiver of the right to counsel is not subject to harmless-error analysis, we reverse.3 The trial court should refrain from disparaging the defendant's choice to waive counsel Finally, we must note our strong disapproval of the trial court's tone in addressing Miles when he first sought to proceed pro se. The trial court warned Miles that self-representation was "a bonehead move,”
1 later decision quote this exact passage · from the dissent
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.