114 Wash. 2d 613 - State v. Swan’s Empirical Analysis
1990
Citation profile
15 federal appellate · 2 district · 263 state decisions
How this case has been cited
Cited by 291 later decisions — most recently March 2025 · most notably 122 Wash. 2d 1 - Matter of Personal Restraint of Young (1993), State v. Stenson (1997)
15 federal appellate · 2 district · 263 state decisions — followed in 10 states
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 Ohio v. Roberts · Carnegie v. United States · Dutton v. Evans · Barber v. Page · Coy v. Iowa
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 291 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"`The most effective types of corroboration in such cases, of course, are eyewitness testimony, a confession or admissions by the accused, and medical or scientific testimony documenting abuse. In most cases of child sexual abuse, however, there is no direct physical or testimonial evidence. The child victim is often the only eyewitness to the crime, and physical corroboration is rare because the sex offenses committed against children tend to be nonviolent offenses such as petting, exhibitionism, fondling and oral copulation. Physical corroboration may also be unavailable because most children do not resist, either out of ignorance or out of respect for authority. Consequently, in order to give any real effect to the child victim hearsay statute, the corroboration requirement must reasonably be held to include indirect evidence of abuse. Such evidence has included a child victim's [abnormal and sexualized behavior,] precocious knowledge of sexual activity, a semen stain on a child's blanket, a child's nightmares and psychological evidence.'" 351 N.J.Super. at 436 , 798 A.2d 673 (quoting State v. Swan, 114 Wash.2d 613, 622-23 , 790 P.2d 610 [1990], cert. denied 498 U.S. 1046 , 111 S.Ct. 752 , 112 L.Ed.2d 772 [1992]).”
7 later decisions quote this exact passage“If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training or education, may testify thereto in the form of an opinion or otherwise.”
7 later decisions quote this exact passage“strongly suggests to a court that the argument or event in question did not appear critically prejudicial to an appellant in the context of the trial.”
7 later decisions 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.