Turner v. State’s Empirical Analysis
2008
Citation profile
2 federal appellate · 37 state decisions
How this case has been cited
Cited by 41 later decisions (2 by the Supreme Court) — most recently May 2024 · most notably Guajardo v. State (2011), McELRATH v. State (2020)
2 federal appellate · 37 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 United States v. Powell · Milam v. State · Dumas v. State · Jones v. State · Jackson 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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“appellate courts cannot know and should not speculate why a jury acquitted on one offense and convicted on another offense. The reason could be an error by the jury in its consideration or it could be mistake, compromise, or lenity. Stated another way, it is imprudent and unworkable to allow criminal defendants to challenge inconsistent verdicts on the ground that in their case the verdict was not the product of lenity, but of some error that worked against them. Such an individualized assessment of the reason for the inconsistency would be based either on pure speculation, or would require inquiries into the jury’s deliberations that the courts generally will not undertake.”
8 later decisions quote this exact passage“when instead of being left to speculate about the unknown motivations of the jury the appellate record makes transparent the jury’s reasoning”). Compare State v. Grey, 147 N.J. 4 , 685 A.2d 923 (1996) (holding that”
6 later decisions quote this exact passage“[I]nconsistent verdicts could be the result of jury mistake, compromise, or lenity, but it is unknown whether the mistake, compromise, or lenity was exercised in favor of the defendant or the prosecution. In our cases endorsing the abolition of the inconsistent verdict rule, we have determined it is not generally within the court's power to make inquiries into the jury's deliberations, or to speculate about the reasons for any inconsistency between guilty and not guilty verdicts.”
1 later decision quote this exact passagee.g. McCullough 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.