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← 214 GAAPP 174 - State v. Berky

State v. Berky’s Empirical Analysis

1994

Citation profile

15
cited by 15 later decisions
2
states following
July 2003
most recently cited

15 state decisions

Relationships

Relies on Ohio Bureau of Employment Services v. Hodory · Eisenstadt v. Baker · 92 Ga. App. 207 - Steve M. Solomon, Jr., Inc. v. Edgar · Franklin v. State · 231 Cal. App. 2d 388 - South Santa Clara Valley Water Conservation District v. Johnson

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. “Authentication of the subject videotape is always required. However, the foundational requirements for the admissibility of videotapes under the silent witness theory [do not mandate a showing of each of] the requirements stated in Allen [ v. State, 146 Ga. App. 815 ], supra. While, the admission of evidence is within the discretion of the trial court, the following three elements must be established: (1) expert testimony establishing that the videotape had not been altered or manipulated; (2) testimony establishing the date and place the videotape was taken; and (3) testimony establishing the identity of the relevant participants depicted. [Cits.]”
    2 later decisions quote this exact passage
  2. “Under the silent witness theory, a videotape constitutes independent probative evidence of what it shows. People v. Byrnes, 398 NE2d 435, 437 (N. Y. 1974).”
    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.