Stewart v. State’s Empirical Analysis
2003
Citation profile
38 state decisions
How this case has been cited
Cited by 38 later decisions — most recently June 2022 · most notably Atlanta Humane Society v. Harkins (2004), Heard v. State (2010)
38 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 Jarrell v. State · Dingler v. State · Catchings v. State · Coats v. State · Bland v. State
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] trial court must first determine whether the offenses are joined solely because they are of the same or similar character. If they are, severance is mandatory. If they are not, the court must then decide whether severance would promote a just determination of guilt or innocence as to each offense. Terry v. State, 259 Ga. 165, 167 (1) ( 377 SE2d 837 ) (1989); Dingier v. State, [ 233 Ga. 462 ( 211 SE2d 752 ) (1975)].”
2 later decisions quote this exact passage“If the charges are joined solely because they are of the same or similar character, a defendant has an absolute right to sever. [Cits.] . . . [However,] offenses have not been joined solely because they are of the same or similar character when evidence of one offense can be admitted upon the trial of another, i.e., when they are so strikingly similar as to evidence a common motive, plan, scheme or bent of mind. [Cits.] (Emphasis in original.)”
1 later decision quote this exact passagee.g. Heard v. State“The fact that evidence of one offense would be admissible in a trial of another offense is a relevant consideration in determining whether to sever, [cit.], but it does not end the inquiry. A trial court must still determine if severance of the offenses would promote a fair [and intelligent] determination of guilt or innocence as to each offense. [Cit.]”
1 later decision quote this exact passagee.g. Heard 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.