114 Wash. 2d 77 - State v. Rempel’s Empirical Analysis
1990
Citation profile
102 state decisions
How this case has been cited
Cited by 104 later decisions — most recently January 2024 · most notably 124 Wash. 2d 702 - State v. Ortega-Martinez (1994), 81 Wash. App. 425 - State v. Hayes (1996)
102 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 · Bibby v. United States · 94 Wash. 2d 216 - State v. Green · 104 Wash. 2d 412 - State v. Guloy · 100 Wash. 2d 889 - State v. Koloske
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 104 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he standard of review is whether, after viewing the evidence in a light most favorable to the State, any rational trier of fact could have found the essential elements of the charged crime beyond a reasonable doubt.”
7 later decisions quote this exact passage“[Rempel’s] words do not contain a request to withhold testimony.... The words “drop the charges” reflect a lay person’s perception that the complaining witness can cause a prosecution to be discontinued. [Rempel] maintained this [false] belief even after [the victim] told him that she did not have any control over the matter. [We acknowledge that] an attempt to induce a witness to withhold testimony does not depend only upon the literal meaning of the words used. The State is entitled to rely on the inferential meaning of the words and the context in which they were used ... including] the prior relationship between [the defendant] and [the witness], and [the witness’s] reaction to the [words]. [But the] entire context [in this case] negates any inference that [Rem-pel’s] request to “drop the charge” was in fact an inducement to withhold testimony from a later trial. [[Image here]] We do not hold that the words “drop the charges” [cannot] sustain a conviction [for witness tampering,] if uttered in a factual context that would lead to a reasonable inference that the speaker actually attempted to induce a witness to [unlawfully] withhold testimony. Given the context here, however, we conclude that no such inference can be drawn. The evidence does not support [Rempel’s] conviction.”
1 later decision quote this exact passagee.g. Rantala v. State“hold that the words `drop the charges' cannot sustain a conviction if uttered in a factual context which would lead to a reasonable inference that the speaker actually attempted to induce a witness to withhold testimony.”
1 later decision quote this exact passagee.g. State v. Gill
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.