State v. Coombs’s Empirical Analysis
1998
Citation profile
2 federal appellate · 30 state decisions
How this case has been cited
Cited by 32 later decisions — most recently August 2025 · most notably State v. Lockhart (2003), Coombs v. Maine (2000)
2 federal appellate · 30 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
Applies 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Miranda v. State of Arizona Vignera · Arizona v. Fulminante · North Carolina v. Butler · Miller v. Fenton · Bram 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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A confession motivated by a promise of leniency by a person with apparent authority' to execute the promise is involuntary and inadmissible. State v. Tardiff, 374 A.2d 598 , 601 (Me.1977). At the suppression hearing, Sergeant Carter testified that he ' did not promise Coombs anything in exchange for her confession and, although he conceded that he flushed the marijuana down the toilet, he denied telling Coombs that she would not be charged with possession if she confessed to the theft. Although Coombs testified to the contrary, the suppression judge, as the fact finder, was free to accept Sergeant Carter’s testimony over Coombs’. See State v. Larrivee, 479 A.2d 347 , 349 (Me.1984); State v. Knights, 482 A.2d 436 , 442 (Me.1984). The trial court’s finding is based on competent evidence and is not clearly erroneous.”
1 later decision quote this exact passagee.g. Coombs v. Maine“[T]he nature of [the] inquiry itself lends support to the conclusion that “volun-tariness” is a legal question meriting independent consideration in a federal habeas corpus proceeding. Although sometimes framed as an issue of “psychological fact,” the dispositive question of the voluntariness of a confession has always had a uniquely legal dimension.”
1 later decision quote this exact passage“Whether a defendant has validly waived her Miranda rights depends on the factual circumstances of the interrogation.”
1 later decision quote this exact passagee.g. State v. Hopkins
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.