In Re Heston’s Empirical Analysis
1998
Citation profile
135 state decisions
How this case has been cited
Cited by 136 later decisions — most recently September 2025 · most notably Jones v. Arkansas Department of Human Services (2005), 149 Ohio App. 3d 717 - In Re Baby Girl Doe (2002)
135 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 · Stanley v. Illinois · McMann v. Richardson · C. E. Morris Co. v. Foley Construction Co. · Lockhart v. Fretwell
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 136 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Where the proceeding contemplates the loss of parents' `essential' and `basic' civil rights to raise their children, * * * the test for ineffective assistance of counsel used in criminal cases is equally applicable to actions seeking to force the permanent, involuntary termination of parental custody.”
18 later decisions quote this exact passage · from the majority“must show that counsel's performance was deficient and that * * * the deficient performance was so serious as to deprive [her] * * * of * * * a trial whose result is reliable.”
1 later decision quote this exact passage · from the majority“The right to counsel, guaranteed in these proceedings by R.C. 2151.352 and by Juv.R 4, includes the right to the effective assistance of counsel.”
1 later decision quote this exact passage · from the majority
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.