State v. Sapp’s Empirical Analysis
2004
Citation profile
200 state decisions
How this case has been cited
Cited by 201 later decisions — most recently July 2025 · most notably State v. Roberts (2006), State v. Montgomery (Slip Opinion) (2016)
200 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 · Williams v. Taylor · State v. Bradley · Ring v. Arizona · Colorado v. Connelly
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 201 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he defendant must show (1) deficient performance by counsel, i.e., performance falling below an objective standard of reasonable representation, and (2) resulting prejudice, i.e., a reasonable probability that, but for counsel's errors, the proceeding's result would have been different.”
9 later decisions quote this exact passage“An alleged error is plain error only if the error is `obvious,' State v. Barnes (2002), 94 Ohio St.3d 21 , 27 , 2002-Ohio-68 , 759 N.E.2d 1240 , and `but for the error, the outcome of the trial clearly would have been otherwise.' State v. Long (1978), 53 Ohio St.2d 91 , 372 N.E.2d 804 , paragraph two of the syllabus.”
4 later decisions quote this exact passage“if the offenses charged * * * are of the same or similar character, or are based on the same act or transaction, or are based on two or more acts or transactions connected together or constituting parts of a common scheme or plan, or are part of a course of criminal conduct.”
3 later decisions 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.