State v. Ayers’s Empirical Analysis

Citation profile

39 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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In 2006, the General Assembly amended Ohio’s DNA testing statutes. The amendments, among other things, made postconviction DNA testing more available to inmates and lowered the outcome-determinative standard for establishing entitlement to DNA testing. Under the prior version of R.C. 2953.71(L), “outcome determinative” meant that had “the results of DNA testing been presented at the trial * * * and been found relevant and admissible with respect to the felony offense for which the inmate * * * is requesting the DNA testing * * * no reasonable factfinder would have found the inmate guilty of that offense.” Under the amended statute, “ ‘outcome determinative’ means that had the results of DNA testing of the subject inmate been presented at the trial * * * and been found relevant and admissible with respect to the felony offense for which the inmate * * * is requesting the DNA testing * * *, and had those results been analyzed in the context of and upon consideration of all available admissible evidence related to the inmate’s case * * *, there is a strong probability that no reasonable factfinder would have found the inmate guilty of that offense.” (Emphasis added.) R.C. 2953.71(L). The addition of the words “strong probability,” among others, in the current version of R.C. 2953.71(L), in essence lowers the definition of “outcome determinative” from a showing of innocence beyond a reasonable doubt to one of clear and convincing evidence. Although there is no legislative stateme”

   2 later decisions quote this exact passage
   e.g. Jackson v. State · State v. Foster

2. “Given the efficacy of DNA testing as an investigative tool in criminal cases, we conclude for purposes of res judicata that DNA testing is a “specialized situation” in which the fear of wrongful conviction outweighs any judicial economy concerns.”

   1 later decision quote this exact passage
   e.g. Jackson v. State