State v. Salamon’s Empirical Analysis

2008

Citation profile

313

cited by 313 later decisions

states following

March 2026

most recently cited

2 federal appellate · 308 state decisions

How this case has been cited

Cited by 313 later decisions — most recently March 2026 · most notably State v. Kitchens (2011), State v. DeJesus (2008)

2 federal appellate · 308 state decisions — followed in 14 states

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 Payne v. Tennessee · Bowsher v. Merck & Co. · Connecticut v. Johnson · State v. Williams · State v. Logan

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 313 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

“Our legislature, in replacing a single, broadly worded kidnapping provision with a gradated scheme that distinguishes kidnappings from unlawful restraints by the presence of an intent to prevent a victim's liberation, intended to exclude from the scope of the more serious crime of kidnapping and its accompanying severe penalties those confinements or movements of a victim that are merely incidental to and necessary for the commission of another crime against that victim. Stated otherwise, to commit a kidnapping in conjunction with another crime, a defendant must intend to prevent the victim's liberation for a longer period of time or to a greater degree than that which is necessary to commit the other crime.”
15 later decisions quote this exact passage · from the dissent
e.g. 184 Conn. App. 101 - Bell v. Commissioner of Correction · 184 Conn. App. 150 - Bell v. Commissioner of Correction
“[ A ] defendant may be convicted of both kidnapping and another substantive crime if, at any time prior to, during or after the commission of that other crime, the victim is moved or confined in a way that has independent criminal significance, that is, the victim was restrained to an extent exceeding that which was necessary to accomplish or complete the other crime.”
15 later decisions quote this exact passage · from the concurrence
e.g. 184 Conn. App. 101 - Bell v. Commissioner of Correction · 184 Conn. App. 150 - Bell v. Commissioner of Correction
“A person is guilty of unlawful restraint in the first degree when he restrains another person under circumstances which expose such other person to a substantial risk of physical injury.”
6 later decisions quote this exact passage · from the concurrence
e.g. 167 Conn. App. 851 - Kitchens v. Commissioner of Correction · 172 Conn. App. 820 - State v. Williams

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.