State v. Vitale’s Empirical Analysis
1985
Citation profile
292 state decisions
How this case has been cited
Cited by 292 later decisions — most recently August 2025 · most notably State v. Golding (1989), State v. Leecan (1986)
292 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 Miranda v. State of Arizona Vignera · Rhode Island v. Innis · Massiah v. United States · Oregon v. Mathiason · Beckwith v. United States
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 292 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a]ny statement given freely and voluntarily without any compelling influences is, of course, admissible in evidence. . . . `Interrogation,' as conceptualized in the Miranda opinion, must reflect a measure of compulsion above and beyond that inherent in custody itself. . . . Voluntary statements of any kind are not barred by the fifth amendment.”
2 later decisions quote this exact passage“Any statement given freely and voluntarily without any compelling influences is, of course, admissible in evidence.”
2 later decisions quote this exact passage“refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.... A practice that the police should know is reasonably likely to evoke an incriminating response from a suspect thus amounts to interrogation. But, since the police surely cannot be held accountable for the unforeseeable results of their words or actions, the definition of interrogation can extend only to words or actions on the part of police officers that they should have known were reasonably likely to elicit an incriminating response.”
1 later decision quote this exact passagee.g. State v. Edwards
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.