12 Cal. 4th 415 - People v. Lucas’s Empirical Analysis
1995
Citation profile
361 state decisions
How this case has been cited
Cited by 374 later decisions — most recently July 2025 · most notably 18 Cal. 4th 297 - People v. Bolin (1998), 16 Cal. 4th 153 - People v. Williams (1997)
361 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 · Miranda v. State of Arizona Vignera · Chambers v. Mississippi · Massiah v. United States · 46 Cal. 2d 818 - People v. Watson
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 374 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Evidence Code section 1230 provides that the out-of-court declaration of an unavailable witness may be admitted for its truth if the statement, when made, was against the declarant's penal interest. The proponent of such evidence must show `that the declarant is unavailable, that the declaration was against the declarant's penal interest, and that the declaration was sufficiently reliable to warrant admission despite its hearsay character.'”
2 later decisions quote this exact passage“'is merely to determine whether there is evidence sufficient to permit a jury to decide the question.'”
2 later decisions quote this exact passage“The focus of the declaration against interest exception to the hearsay rule is the basic trustworthiness of the declaration. [Citations.] In determining whether a statement is truly against interest within the meaning of Evidence Code section 1230, and hence is sufficiently trustworthy to be admissible, the court may take into account not just the words but the circumstances under which they were uttered, the possible motivation of the declarant, and the declarant's relationship to the defendant.”
1 later decision 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.