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← 158 Vt. 173 - State v. Sims

State v. Sims’s Empirical Analysis

1991

Citation profile

43
cited by 43 later decisions
2
states following
March 2025
most recently cited

43 state decisions

How this case has been cited

Cited by 43 later decisions — most recently March 2025 · most notably In re Carter (2004), State v. Kinney (2000)

43 state decisions

1801991200020102020decided

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 Brady v. United States · McKaskle v. Wiggins · United States v. Gonzalez · State v. Spigarolo · United States v. Halbert

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

  1. “When the substance of the testimony in this case is compared with that in the foregoing cases, it is difficult to conclude that plain error was committed here. In [State v.] DeJoinville, no plain error was found despite the fact that the expert expressly testified about the credibility of child sexual abuse complainants. 145 Vt. [603,] 604, 496 A.2d [173,] 174 [(1985)]. In [State v.] Recor, the expert stated that the consistency of a child's statements "gives me a sense that what they are saying happened, happened." 150 Vt. [40,] 45, 549 A.2d [1382,] 1386 [(1988)]. In [ State v.] Ross , the expert not only detailed the complainant's sexual activity with the defendant as told to her by the complainant, and not only stated that young children do not fabricate stories of sexual abuse, but also expressly concluded that the complainant had been sexually abused by the defendant. 152 Vt. [462,] 467-68, 568 A.2d [335,] 339 [(1989)].”
    1 later decision quote this exact passage
  2. “A defendant’s acceptance of responsibility for the offense, and a sincere demonstration of remorse, are proper considerations in sentencing. They constitute important steps toward rehabilitation. Where they are present, a reduction in sentence can be appropriate. Likewise, denying this reduction, where there are no acknowledgements, can be appropriate and does not penalize a defendant’s privilege against self-incrimination. We “‘are unprepared to equate the possibility of leniency with impermissible punishment.’” United States v. Parker, 903 F.2d 91, 105 (2d. Cir. 1990) (quoting United States v. Henry, 883 F.2d 1010, 1011 (11th Cir. 1989) (per curiam)).”
    1 later decision quote this exact passage
  3. “This Court has never found an expert's impermissible comment on a child sexual abuse complainant's credibility to be plain error.”
    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.