Evans v. State’s Empirical Analysis
1973
Citation profile
55 state decisions
How this case has been cited
Cited by 55 later decisions — most recently April 2013 · most notably Murphy v. State (1977), Howard v. State (1976)
55 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 Dusky v. United States · Pate v. Robinson · Smith v. State · Hill v. State · Floyd v. United States
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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“On the other hand we do not believe that the issue of competency should always be irrevocably dissolved simply because nothing during the time frame [pretrial to sentencing] . . . gave rise to doubts about an appellant's competency, regardless of the significance of the post trial disclosurés and their relevance to possible incompetency at the time of trial. In certain unique situations facts coming to light only after the trial may be so significant and compelling as to create 'reasonable grounds' to question a defendant's competency at the time of his trial and therefore require a hearing on the question.”
2 later decisions quote this exact passage · from the majority“When we have a situation such as this where the trial process has been completed without any apparent indications of incompetency on the part of appellant the verdict of a court should not be lightly disturbed. The relevant issue is, after all, appellant's ability to understand the proceedings and consult with his attorney and if any doubt concerning his ability to do so are to become apparent they would normally do so when he is in the process of performing these functions. However as we have held in a recent opinion: "On the other hand we do not believe that the issue of competency should always be irrevocably dissolved simply because nothing during the time frame [pretrial to sentencing] . . . gave rise to doubts about an appellant's competency, regardless of the significance of the post trial disclosurés and their relevance to possible incompetency at the time of trial. In certain unique situations facts coming to light only after the trial may be so significant and compelling as to create 'reasonable grounds' to question a defendant's competency at the time of his trial and therefore require a hearing on the question." Tinsley v. State, [ 298 N.E.2d 429 (Ind. 1973)].”
1 later decision quote this exact passage · from the majority““[O]ne who may be incompetent to stand trial cannot be held to have knowingly and intelligently waived his right to a hearing on the matter by his failure to assert it at trial. The peculiar nature of the question of competency precludes the application of the usual waiver theory to it. Pate v. Robinson (1966), 383 U.S. 375 , 86 S.Ct. 836 , 15 L.Ed.2d 815 ; Tinsley v. State (1973), 260 Ind. 577 , 298 N.E.2d 429, fn. 1 . The essential point in this case therefore becomes the competency of appellant. His ability to waive certain rights must first be decided before a waiver of them can be attributed to him since the answer to whether appellant has waived any defense of insanity he may have had must turn on the question of his competency at the time of trial.” 261 Ind. at 158 .”
1 later decision quote this exact passage · from the majoritye.g. Henson 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.