State v. Luurtsema’s Empirical Analysis
2002
Citation profile
81 state decisions
How this case has been cited
Cited by 81 later decisions — most recently June 2025 · most notably State v. Salamon (2008), State v. Kitchens (2011)
81 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 Miranda v. State of Arizona Vignera · Wong Sun v. United States · Brown v. Illinois · United States v. Calandra · Nardone 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 81 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he proper inquiry is not whether the kidnapping was incidental to [other offenses], but whether the restraint was accomplished with the requisite intent to constitute kidnapping, as well as the state of mind required for [the other offenses]. Whether the essential elements of kidnapping are proved beyond a reasonable doubt is a question for the jury.... The analysis, therefore, is not simply transactional. A defendant may be convicted of two crimes that derive from the same conduct as long as the state [is] able to prove, beyond a reasonable doubt, all of the essential elements of each crime.”
1 later decision quote this exact passage · from the concurrencee.g. State v. DeJesus“all that is required under the statute is that the defendant have abducted the victim and restrained her with the requisite intent.... Under the aforementioned definitions [of abduct and restrain], the abduction requirement is satisfied when the defendant restrains the victim with the intent to prevent her liberation through the use of physical force.”
1 later decision quote this exact passage · from the concurrence“[W]here the police have probable cause to arrest a suspect, the exclusionary rule does not bar the State's use of a statement made by the defendant outside of his home, even though the statement is taken after an arrest made in the home in violation of Payton.”
1 later decision quote this exact passage · from the concurrencee.g. State v. Roberson
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.