Jenkins v. State’s Empirical Analysis
2004
Citation profile
61 state decisions
How this case has been cited
Cited by 61 later decisions — most recently October 2023 · most notably Lindsey v. State (2007), State v. Hembertt (2005)
61 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 Crawford v. Washington · Distilled Spirits · Hall v. Hopper · Moody v. State · James 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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he tolling exception to the statute of limitations cannot be based upon the subjective opinion of the district attorney as to whether there was enough evidence to file charges against a particular person. Otherwise, there would be tolling of the statute of limitations for routine investigation into a crime; the State could build a case against a non- murder suspect for five or ten years and then file charges when it believes that it has obtained sufficient evidence by claiming that the statute of limitations was tolled until that moment. Such a broad interpretation of the tolling period would permit the exception to swallow the rule. The evidence shows that the State had actual knowledge of [the defendant]’s identity as a suspect for the crimes shortly after they were committed, but it did not indict him until more than seven years had elapsed. Therefore, we affirm the trial court’s ruling on the dismissal of the non-murder charges due to the expiration of the statute of limitations.”
3 later decisions quote this exact passage“[T]he burden is unquestionably upon the State to prove that a crime occurred within the statute of limitation, or, if an exception to the statute is alleged, to prove that the case properly falls within the exception. Thus, although the statute of limitation is not an element of the crime, per se, in a prosecution, where an exception is relied upon to prevent the bar of the statute of limitation, it must be alleged and proved .”
1 later decision quote this exact passage
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.