State v. Mizenko’s Empirical Analysis
2006
Citation profile
87 state decisions
How this case has been cited
Cited by 87 later decisions — most recently November 2025 · most notably State v. Stahl (2006), State v. Derbyshire (2009)
87 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 Crawford v. Washington · Ohio v. Roberts · Pointer v. Texas · California v. Green · Dutton v. Evans
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 87 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Roberts test allows a jury to hear evidence, untested by the adversary process, based on a mere judicial determination of reliability. It thus replaces the constitutionally prescribed method of assessing reliability with a wholly foreign one. In this respect, it is very different from exceptions to the Confrontation Clause that make no claim to be a surrogate means of assessing reliability. For example, the rule of forfeiture by wrongdoing (which we accept) extinguishes confrontation claims on essentially equitable grounds; it does not purport to be an alternative means of determining reliability. See Reynolds v. United States, 98 U.S. 145, 158-59 (187[8]).”
1 later decision quote this exact passage · from the concurrencee.g. State v. Jensen“even though the declarant is available as a witness . . . [a] statement relating to a startling event or condition made while the declarant was under the stress of excitement caused by the event or condition”
1 later decision quote this exact passage · from the concurrencee.g. In Re TW“when a declarant speaks with her neighbor across the backyard fence, she has much less of an expectation that the government will make prosecuto-rial use of those statements.”
1 later decision quote this exact passage · from the concurrencee.g. State v. Jensen
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.