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← 1997 ND 188 - State v. Hart

State v. Hart’s Empirical Analysis

1997

Citation profile

31
cited by 31 later decisions
1
states following
November 2024
most recently cited

31 state decisions

How this case has been cited

Cited by 31 later decisions — most recently November 2024 · most notably Owens v. State (1998), State v. Harmon (1998)

31 state decisions

1701997200020102020decided

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 Faretta v. California · McKaskle v. Wiggins · State v. Leidholm · State v. Manke · State v. Dokken

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

  1. “The right of self-representation is not a license to abuse the dignity of the courtroom. Neither is it a license not to comply with relevant rules of procedural and substantive law. Thus, whatever else may or may not be open to him on appeal, a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of “effective assistance of counsel.””
    1 later decision quote this exact passage
  2. “Foster at ¶ 14 . The trial court did not abuse its discretion in refusing to appoint substitute counsel. IV [¶ 15] Harmon argues he did not waive his Sixth Amendment right to assistance of counsel because the trial court failed to advise him of the dangers of proceeding pro se and the record shows no”
    1 later decision quote this exact passage
  3. “[a] knowing and intelligent waiver of the right to counsel depends on the facts and circumstances and requires the defendant to be made aware of the dangers and disadvantages of self-representation so the record establishes the defendant knows what he is doing and his choice is made with eyes open.”
    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.