State v. Manewa’s Empirical Analysis

Citation profile

12 state decisions

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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[The chemist] lacked personal knowledge that the balance had been correctly calibrated and merely assumed that the manufacturer’s service representative had done so. The service representative did not testify at trial regarding his calibration of the balance, nor did the prosecution, through a custodian of records, offer any business record of the manufacturer reflecting proper calibration of the balance. There being no reliable evidence showing that the balance was “in proper working order,” the prosecution failed to lay “a sound factual foundation” that the net weight of the cocaine measured by the balance was accurate. Therefore, because inadequate foundation was laid to show that the weight measured by the balance could “be relied on as a substantive fact,” [the chemist’s] assumption that the balance was accurate was based on inadmissible hearsay. Accordingly, we hold that the circuit court clearly abused its discretion in admitting [the chemist’s] testimony regarding the net weight of the cocaine.”

   1 later decision quote this exact passage · from the majority
   e.g. State v. Fitzwater.

2. “[ (1) ] that [whoever conducted the test] had any training or expertise in calibrating the [testing device], (2) that the [testing device] had been properly calibrated by the manufacturer’s service representatives, (3) that there was an accepted manufacturer's established procedure for “verifying and validating” that the [testing device] was in proper working order and that if such a procedure existed, that [the operator] followed it, and (4) that [the testing device] was in proper working order at the time the [speedometer] was [checked].”

   1 later decision quote this exact passage · from the majority
   e.g. State v. Fitzwater.

3. “HRS § 701-114(1)(a) and (b) (1993) requires proof beyond a reasonable doubt of each element of the offense, as well as the state of mind required to establish each element of the offense.”

   1 later decision quote this exact passage · from the majority
   e.g. State v. Kalaola