State v. Rose’s Empirical Analysis
1980
Citation profile
45 state decisions
How this case has been cited
Cited by 45 later decisions — most recently November 2025 · most notably State v. Boyer (1985), Vernon Kills on Top v. State (1996)
45 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 Aguilar v. Texas · McMann v. Richardson · Wardius v. Oregon · Roberts v. Florida · Cooper v. Fitzharris
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 45 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Persons accused of crime are entitled to the effective assistance of counsel acting within the range of competence demanded of attorneys in criminal cases.” State v. Rose, 608 P.2d at 1081 .”
3 later decisions quote this exact passage · from the majority““ ‘Persons accused of crime are entitled to the effective assistance of counsel acting within the range of competence demanded of attorneys in criminal cases.’ ” State v. Rose (1980), Mont., 608 P.2d at 1081 , 37 St.Rep. at 649-650; Fitzpatrick v. State (1981), Mont., 638 P.2d 1002, 1007 , 38 St.Rep. 1448 , 1451; Cooper v. Fitzharris (9th Cir.1978) 586 F.2d 1325, 1330 . “ ‘Claimed inadequacy of counsel must not be tested by a greater sophistication of appellate counsel, nor by that counsel’s unrivaled opportunity to study the record at leisure and cite different tactics of perhaps doubtful efficacy. Success is not a test of efficient counsel, frequently neither vigor, zeal, nor skill can overcome the truth.’ ” State v. Rose, 608 P.2d at 1082 , 37 St.Rep. at 652; State v. Forsness (1972), 159 Mont. 105, 110 , 495 P.2d 176, 178-179 .”
1 later decision quote this exact passage · from the majoritye.g. State v. Morigeau““Where the claim of ineffective assistance of counsel rests upon specific acts and omissions of counsel at trial, as it does in this case, relief will be granted only if it appears that the defendant was prejudiced by counsel’s conduct.” State v. Rose, 608 P.2d 1081 .”
1 later decision quote this exact passage · from the majoritye.g. State v. LaValley
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.