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← 1998 ND 88 - State v. Poitra

State v. Poitra’s Empirical Analysis

1998

Citation profile

15
cited by 15 later decisions
1
states following
December 2025
most recently cited

14 state decisions

How this case has been cited

Cited by 15 later decisions — most recently December 2025

14 state decisions

601998200020102020decided

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 · Gideon v. Wainwright · Argersinger v. Hamlin · Hendricks v. Zenon · Bowden v. State

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

  1. “than to represent himself because he was unable to secure a loan to hire an attorney. Id. at ¶ 4. During the trial, Poitra represented himself and was subsequently convicted of theft of property. Id. at ¶ 5. [¶ 13] On appeal, Poitra argued the trial court failed to advise him of the dangers and disadvantages of proceeding pro se, and thus, he did not knowingly and intelligently waive his right to counsel. Id. at ¶ 6. This court concluded Poitra's statement that he had”
    1 later decision quote this exact passage
  2. “a specific colloquy about the dangers and disadvantages of self-representation is not required, but trial courts should eliminate any ambiguity about functional waivers by making a specific on-the-record determination that the defendant unequivocally, knowingly, and intelligently waived the right to counsel.”
    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.