State v. Eid.’s Empirical Analysis

Citation profile

10 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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The denial of a motion in limine, in itself, is not a reversible error. The harm, if any, occurs when the evidence is improperly admitted at trial.”

   3 later decisions quote this exact passage · from the majority
   e.g. Kobashigawa v. Silva. · Goran Pleho, LLC v. Lacy. ICA mem.op., filed 07/29/2016. Motion for Partial Reconsideration of Memorandum Opinion, filed 08/08/2016.

2. “[T]he State established that the persons conducting the speed check were qualified by experience to operate the device. The State established at the pretrial hearing that only Roy and Duane, experienced auto mechanics, performed speed checks on HPD vehicles in 2007. The district court qualified Roy as an automotive vehicle expert and a motor vehicle mechanic dealer expert and qualified Duane as an expert in the fields of automotive mechanics and repair and automotive technology. Although Roy did not receive specific training on how to use the speedometer dynamometer, Roy testified that “for a mechanic, it’s pretty straightforward.” Notably, Eid’s expert witness, Ho, similarly testified that he was not aware of any certification, school, or formal training for operating or using a speedometer dynamometer. Rather, Ho testified that a person would gain knowledge about a speedometer dynamom-eter by using it and through experience. By showing that the speedometer dyna-mometer was in proper working order and used by qualified mechanics in conducting the speed checks, the State provided adequate assurances that the results of the speed checks were reliable.... .... While the manufacturer of the rollers and cable was not established, the absence of that information was not material, since their operation was straightforward and within the expertise of Roy and Duane as licensed mechanics.”

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

3. “When a question arises regarding the necessary foundation for the introduction of evidence, the determination of whether proper foundation has been established lies within the discretion of the trial court, and its determination will not be overturned absent a showing of clear 5 Hufana was called as a witness by both the State and Leus. Leus's attempt to introduce Exhibit 4U into evidence, as a prior inconsistent statement, occurred during his direct examination of Hufana on December 7, 2017. Hufana had previously been called by the State to testify on December 6, 2017. 6 HRE Rule 613(b) instructs, in pertinent part, Extrinsic evidence of a prior inconsistent statement by a witness is not admissible unless, on direct or crossexamination, (1) the circumstances of the statement have been brought to the attention of the witness, and (2) the witness has been asked whether the witness made the statement. HRE Rule 613. HRE Rule 802.1 recognizes an inconsistent statement as an exception to the hearsay rule when, among other things, "the statement is offered in compliance with rule 613(b)[.]”

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