Hartsfield v. Commonwealth’s Empirical Analysis
2009
Citation profile
1 federal appellate · 21 state decisions
How this case has been cited
Cited by 23 later decisions — most recently November 2025
1 federal appellate · 21 state decisions — followed in 11 states
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 Crawford v. Washington · Ohio v. Roberts · Davis v. Washington · White v. Illinois · Commonwealth v. English
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Statements are non-testimonial when made in the course of police interrogation under circumstances objectively indicating that the primary purpose of the interrogation is to enable police assistance to meet an ongoing emergency. They are testimonial when the circumstances objectively indicate that there is no such ongoing emergency, and that the primary purpose of the interrogation is to establish or prove past events potentially relevant to later criminal prosecution.”
1 later decision quote this exact passage · from the majority“[t]hese statements in the case at hand were spontaneous and unprompted by questioning. These statements were not testimonial because they were not formal, not delivered to law enforcement or its equivalent, and were in the nature of seeking help for an emergency (even though it was not ongoing).”
1 later decision quote this exact passage · from the majority“The SANE nurse under KRS 314.011(14) is made available to ‘victims of sexual offenses,' which makes the SANE nurse an active participant in the formal criminal investigation.”); Medina v. State, 122 Nev. 346 , 143 P.3d 471 , 476 (2006) (concluding SANE nurse”
1 later decision quote this exact passage · from the majoritye.g. McCormick v. Parker
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.