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← 218 Kan. 60 - State v. Haze

State v. Haze’s Empirical Analysis

1975

Citation profile

33
cited by 33 later decisions
2
cited 2 times by the Supreme Court
8
states following
June 2020
most recently cited

31 state decisions

How this case has been cited

Cited by 33 later decisions (2 by the Supreme Court) — most recently June 2020 · most notably South Dakota v. Neville (1983), State v. Henson (1977)

31 state decisions

120197519801990200020102020decided

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 United States v. Wade · Schmerber v. State of California · Gilbert v. California · Earley v. DiCenso · California v. Curry

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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““[T]he mere refusal of the test, standing alone, actually communicated nothing about the accused’s knowledge of the case. . . . [A] verbal communication of the refusal discloses no more of the accused’s protected knowledge than would mere conduct in totally failing to comply with the order or in intentionally distorting one’s handwriting. The express refusal adds little or nothing to the failure to comply and it can scarcely be contended that evidence of the mere act of noncompliance falls within the protection against self-incrimination. The refusal is in substance an indication of the conduct of the accused and it is this conduct, rather than the oral utterance, which provides the basis for the inference of a consciousness of guilt. Thus, the refusal should be treated as an act or conduct indicating consciousness of guilt, rather than a self-incriminating statement. In refusing to supply exemplars, defendant was not communicating anything within the meaning of the Fifth Amendment. He in no way cooperated with, or provided testimony for, his prosecutors by the refusal. On the contrary, he was being as uncooperative as possible and evidence of these actions and his intent to continue them was properly presented to the jury.” (Emphasis added.) 218 Kan. at 63-64 .”
    2 later decisions quote this exact passage · from the majority
  2. “grant no greater protection against self-incrimination than is afforded by the Fifth Amendment to the United States Constitution”
    1 later decision quote this exact passage · from the majority

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.