123 Wash. 2d 877 - State v. Thomson’s Empirical Analysis
1994
Citation profile
3 federal appellate · 29 state decisions
How this case has been cited
Cited by 34 later decisions — most recently December 2025 · most notably Greene v. Lambert (2002), Pinkney v. State (1998)
3 federal appellate · 29 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 Johnson v. Zerbst · United States v. Gagnon · Bethlehem Steel Corp. v. Pemberton · Taylor v. United States · Adair v. United States
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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) make sufficient inquiry into the circumstances of a defendant’s disappearance to justify a finding whether the absence was voluntary, (2) make a preliminary finding of voluntariness, when justified, and (3) afford the defendant an adequate opportunity to explain the absence when the defendant is returned to custody and before sentence is imposed.”
6 later decisions quote this exact passage · from the majority“The procedure ... amply protects the defendant’s rights by assuring that the trial court will examine the circumstances of the defendant’s absence before determining whether the absence is voluntary, and by providing the defendant an opportunity to explain his or her absence before judgment of conviction is formally entered. It allows the court to discontinue the trial if the voluntariness of the defendant’s absence appears doubtful in light of all the circumstances.”
3 later decisions quote this exact passage · from the majoritye.g. State v. Garza · State v. Morgen“[t]he defendant's voluntary absence after the trial has commenced in his or her presence shall not prevent continuing the trial to and including the return of the verdict.”
2 later decisions quote this exact passage · from the majoritye.g. State v. Atherton · State v. Garza
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.