Pavatt v. State’s Empirical Analysis
2007
Citation profile
5 federal appellate · 38 state decisions
How this case has been cited
Cited by 47 later decisions — most recently July 2025 · most notably 2010 OK CR 6 - Simpson v. State (2010), Cuesta-Rodriguez v. State (2010)
5 federal appellate · 38 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 · Jackson v. Virginia · North Carolina v. Pearce · Chambers v. Mississippi · Irvin v. Dowd
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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In Propositions 14 and 15, [Pavatt] challenges the sufficiency of the evidence to support the two aggravating circumstances alleged by the State as warranting the death penalty. Such challenges are reviewed under the same standard as challenges to the evidence supporting a criminal conviction. We consider the evidence in a light most favorable to the State, and determine whether any rational juror could have found the existence of the challenged aggravating circumstance beyond a reasonable doubt. DeRosa [v. State] , 2004 OK CR 19 at ¶ 85, 89 P.3d at 1153 ; Lockett v. State , 2002 OK CR 30 , ¶ 39, 53 P.3d 418 , 430. In Proposition 14, [Pavatt] claims the evidence was insufficient to support the jury's finding that the murder of Rob Andrew was "especially heinous, atrocious, or cruel." To establish this aggravator, the State must present evidence from which the jury could find that the victim's death was preceded by either serious physical abuse or torture. Evidence that the victim was conscious and aware of the attack supports a finding of torture. Davis v. State , 2004 OK CR 36 , ¶ 39, 103 P.3d 70 , 81 ; Black v. State , 2001 OK CR 5 , ¶ 79, 21 P.3d 1047 , 1074 (evidence that victim consciously suffered pain during and after stabbing was sufficient to support this aggravating circumstance); Le [v. State] , 1997 OK CR 55 at ¶ 35, 947 P.2d at 550 ; Romano v. State , 1995 OK CR 74 , ¶ 70, 909 P.2d 92 , 118 ; Berget v. State , 1991 OK CR 121 , ¶ 31, 824 P.2d 364 , 373. Our evalua”
2 later decisions quote this exact passage · from the majority“In the end, the law makes no distinction between direct and cireumstantial evidence; either, or any combination of the two, may be sufficient to support a convietion. Clark v. State, 1983 OK CR 79, ¶ 8 , 664 P.2d 1065, 1066 , OUJI-CR(Znd) No. 9-4. The jury may consider all competent evidence, along with [the] rules of law and basic common sense, in reaching a verdict.”
2 later decisions quote this exact passage · from the majority“a defendant has a right to present competent evidence in his own defense, and . . . rules of evidence may not arbitrarily impinge on that right.”
2 later decisions quote this exact passage · from the majoritye.g. LAMAR v. STATE · Summers v. State
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.