State v. Bode’s Empirical Analysis

Citation profile

55 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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “adjudication of delinquency may not be used to enhance the penalty for a later offense when the adjudication carried the possibility of confinement, the adjudication was uncounseled, and there was no effective waiver of the right to counsel.”

   2 later decisions quote this exact passage
   e.g. State v. Carnes (Slip Opinion) · Bode v. Fairfield Cty. Pros. Atty.'s Office

2. “[T]he General Assembly acknowledged the importance of counsel in juvenile proceedings by codifying a juvenile's constitutional right to appointed counsel through R.C. 2151.352, thus providing 'a statutory right to appointed counsel that goes beyond constitutional requirements.'”

   1 later decision quote this exact passage
   e.g. In re C.M.R.

3. “recognized that the right to counsel 'flows to the juvenile through the Due Process Clause of the Fourteenth Amendment, not the Sixth Amendment.'”

   1 later decision quote this exact passage
   e.g. In re C.M.R.