28 Wash. App. 606 - State v. Burrell’s Empirical Analysis
1981
Citation profile
19 state decisions
How this case has been cited
Cited by 19 later decisions — most recently May 2021
19 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 Simmons v. United States · Neil v. Biggers · Manson v. Brathwaite · 89 Wash. 2d 430 - State v. Hilliard · 81 Wash. 2d 205 - State v. Nettles
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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Insofar as Thorkelson may suggest a per se rule of exclusion, we modify its holding.”
4 later decisions quote this exact passage“absent extenuating circumstances, photographic identification procedures of an in-custody defendant should not be used.”
3 later decisions quote this exact passage“The rule in Thorkelson is a salutary one that reduces the risk of misidentification. The majority's purported modification, of Thorkelson is dicta unnecessary to the decision. The law in this jurisdiction remains that absent extenuating circumstances, a photographic identification procedure should not be used when the defendant is in custody. A violation of this rule requires balancing the inherently corruptive effect of the photo montage and any other suggestiveness against the countervailing indicia of reliability.”
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.