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← 174 Wash. 528 - State v. Kwan

State v. Kwan’s Empirical Analysis

1933

Citation profile

49
cited by 49 later decisions
2
states following
June 2015
most recently cited

2 federal appellate · 45 state decisions

How this case has been cited

Cited by 49 later decisions — most recently June 2015 · most notably 105 Wash. 2d 692 - State v. Kwan Fai Mak (1986), 123 Wash. 2d 296 - Matter of Personal Restraint of Lord (1994)

2 federal appellate · 45 state decisions

120193319401950196019701980199020002010decided

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 People v. Mendez · People v. Glaze · People v. Wilkins · State v. Downs · State v. Schuman

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

  1. “Before such testimony can be received, there must be such proof of connection with the crime, such a train of facts or circumstances as tend clearly to point out someone besides the accused as the guilty party.”
    3 later decisions quote this exact passage
  2. “The fact that the answer was given in response to a direct question does not destroy its spontaneity. Statements, though in answer to a question, are nevertheless spontaneous and instinctive where the surrounding facts and circumstances negative the thought that they might have been made with design or premeditation. Lucchesi v. Reynolds, 125 Wash. 352 , 216 Pac. 12 ; State v. Labbee, 134 Wash. 55 , 234 Pac. 1049 . The evidence in this case shows that the statement was spontaneous and instinctive, and was not made with design or premeditation.”
    1 later decision quote this exact passage
  3. “It is next contended that it was error to permit the police officer to testify, when he arrived, that Bow said that China boys had shot him, for the reason, as it is claimed, that this statement was not a part of the res gestae. The officer giving the testimony arrived at the scene of the homicide a few minutes after the shooting. Bow at this time was lying on the sidewalk, leaning against the steps leading up to a neighbor’s residence.”
    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.