27 Ohio App. 3d 149 - State v. Fowler’s Empirical Analysis
1985
Citation profile
3 federal appellate · 134 state decisions
How this case has been cited
Cited by 141 later decisions — most recently October 2025 · most notably State v. Eskridge (1988), State v. Beuke (1988)
3 federal appellate · 134 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 Chapman v. State of California · California v. Green · Dutton v. Evans · Schneble v. Florida · Mattox 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 141 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[f]orce need not be overt and physically brutal, but can be subtle and psychological.”
14 later decisions quote this exact passage“(2) Excited Utterance. A statement relating to a startling event or condition made while the declarant was under the stress of excitement caused by the event or condition.”
2 later decisions quote this exact passage“(H)When an offender, as part of a course of criminal conduct, commits offenses in different jurisdictions,he may be tried for all such offenses in any jurisdiction in which one such offense or any element thereofoccurred. Without limitation on the evidence which may be used to establish such course of conduct, any of the following is prima-facie evidence of a course of criminal conduct:”
1 later decision quote this exact passagee.g. State v. Hensley
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.