State v. White’s Empirical Analysis
2001
Citation profile
145 state decisions
How this case has been cited
Cited by 145 later decisions — most recently March 2026 · most notably State v. Gunderson (2010), State v. Kougl (2004)
145 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 Strickland v. Washington · Dawson v. State · Hagen v. State · Hans v. State · State v. Matson
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 145 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Though not easily distilled into a formula, the definitive question that distinguishes and decides which actions are record and which are non-record, is why? In other words, if counsel fails to object to the admission of evidence, or fails to offer an opening statement, does the record fully explain why counsel took the particular course of action? If not, then the matter is best-suited for post-conviction proceedings which permit a further inquiry into whether the particular representation was ineffective. Only when the record will fully explain why counsel took, or failed to take, action in providing a defense for the accused may this Court review the matter on direct appeal.”
6 later decisions quote this exact passage · from the majority“[W]here ineffective assistance of counsel claims are based on facts of record in the underlying case, they must be raised in the 4 direct appeal and, conversely, where the allegations of ineffective assistance of counsel cannot be documented from the record in the underlying case, those claims must be raised by petition for post-conviction relief.”
3 later decisions quote this exact passage · from the majoritye.g. State v. Anthony · State v. Upshaw“As for those clearly non-record based areas of representation, this Court has identified counsel’s failure to adequately investigate, or failure to prepare a defense, or failure to familiarize him or herself with critical areas of the applicable law.”
1 later decision quote this exact passage · from the majoritye.g. State v. Becker
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.