State v. Simpson’s Empirical Analysis
2008
Citation profile
91 state decisions
How this case has been cited
Cited by 91 later decisions — most recently August 2025 · most notably State v. Winot (2010), Connecticut Light and Power Co. v. Gilmore (2008)
91 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 · Bethlehem Steel Corp. v. Pemberton · State v. Whelan · State v. Geisler · Wheeler v. MO DIR. OF REVENUE
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 91 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“adopted a hearsay exception allowing the substantive use of prior written inconsistent statements, signed by the declarant, who has personal knowledge of the facts stated, when the declarant testifies at trial and is subject to cross-examination. This rule has also been codified in § 8-5 (1) of the Connecticut Code of Evidence, which incorporates all of the developments and clarifications of the Whelan rule that have occurred since Whelan was decided.... In addition to signed documents, the Whelan rule also is applicable to taperecorded statements that otherwise satisfy its conditions.”
4 later decisions quote this exact passage“In determining whether an inconsistency exists, the testimony of a witness as a whole, or the whole impression or effect of what has been said, must be examined.... Inconsistency in effect, rather than contradiction in express terms, is the test for admitting a witness' prior statement .... A statement's inconsistency may be determined from the circumstances and is not limited to cases in which diametrically opposed assertions have been made.”
2 later decisions quote this exact passage“In State v. Whelan , supra, 200 Conn. at 753 , 513 A.2d 86 ... we adopted a hearsay exception allowing the substantive use of prior written inconsistent statements, signed by the declarant, who has personal knowledge of the facts stated, when the declarant testifies at trial and is subject to cross-examination. This rule has also been codified in § 8-5 (1) of the Connecticut Code of Evidence.... The Whelan hearsay exception applies to a relatively narrow category of prior inconsistent statements ... [and was] carefully limited ... to those prior statements that carry such substantial indicia of reliability as to warrant their substantive admissibility. As with any statement that is admitted into evidence under a hearsay exception, a statement that satisfies the Whelan criteria may or may not be true in fact. But, as with any other statement that qualifies under a hearsay exception, it nevertheless is admissible to establish the truth of the matter asserted because it falls within a class of hearsay evidence that has been deemed sufficiently trustworthy to merit such treatment. Thus ... we allow the fact finder to determine whether the hearsay statement is credible upon consideration of all the relevant circumstances.”
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.