Garza v. State’s Empirical Analysis
2008
Citation profile
2 federal appellate · 145 state decisions
How this case has been cited
Cited by 151 later decisions — most recently May 2021 · most notably Henderson v. State (2009), Brown v. State (2011)
2 federal appellate · 145 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 Jackson v. Virginia · Missouri v. Hunter · Drinkard v. Walker · Hall v. Hopper · Haynes 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 151 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) the duration of the movement; (2) whether the movement occurred during the commission of a separate offense; (3) whether such movement was an inherent part of that separate offense; and (4) whether the movement itself presented a significant danger to the victim independent of the danger posed by the separate offense.”
43 later decisions quote this exact passage · from the concurrence“[assessment of these factors will assist Georgia prosecutors and courts alike in determining whether the movement in question is in the nature of the evil the kidnapping statute was originally intended to address — i.e., movement serving to substantially isolate the victim from protection or rescue — or merely a “criminologically insignificant circumstance” attendant to some other crime.”
13 later decisions quote this exact passage · from the concurrence“[a]s other courts and commentators have noted, and as [the Supreme Court of Georgia] has witnessed, this expansive construction of asportation poses a potential danger that the definition of kidnapping will sweep within its scope conduct that is decidedly wrongful but that should be punished as some other crime. Thus, for example, the robber who forces his victim to move from one room to another in order to find a cashbox or open a safe technically may commit kidnapping as well as robbery. This reasoning raises the possibility of cumulative penalties or of higher sanctions for kidnapping, even though the “removal” of the victim to another place was part and parcel of the robbery and not an independent wrong.”
2 later decisions 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.