Huffington v. State’s Empirical Analysis
1982
Citation profile
2 federal appellate · 56 state decisions
How this case has been cited
Cited by 58 later decisions — most recently October 2021 · most notably Thomas v. State (1984), Hunt v. State (1988)
2 federal appellate · 56 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 Dorsey v. State · Laverick v. United States · Hillard v. State · Johnson v. State · Clay 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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The rule is that the plaintiff will be required to go fully into his own case-in-chief on these issues as to which he holds the substantial affirmative, and where, therefore, the burden of proof rests on him; and hence, in reply to the case made by the defendant, he will ordinarily be limited to what is strictly rebutting evidence. Still, it is not always easy to draw the line between what is rebutting evidence and what is evidence properly adducible in chief. The subject is one which is addressed to the sound discretion of the court; and the appellate court will not reverse for an error on this point, unless the ruling of the court below was both manifestly wrong and substantially injurious. Indeed, as a general rule, in such cases no appeal will lie____ Trials would be greatly prolonged and great surprise and injustice would result if the practice in regards to rebutting evidence was not enforced; and hence, except where departures from the rule seem to be justified by the requirements of particular cases, the courts will not permit evidence to be offered in rebuttal, unless it is really in answer to something which was not properly part of the case-in-chief. If it is testimony merely cumulative to, or corroborative of, that already offered in chief, it will be rejected. (Footnotes omitted.)”
2 later decisions quote this exact passage · from the majority“[r]ebuttal evidence 'includes any competent evidence which explains, or is a direct reply to, or a contradiction of, any new matter that has been brought into the case by the defense.’ Our cases are clear that the question of what constitutes rebuttal testimony rests within the sound discretion of the trial court, and that the court’s ruling should be reversed only where shown to be both ‘manifestly wrong and substantially injurious.' Even if the trial court clearly rules that certain testimony is not rebuttal evidence, the court may nonetheless exercise its discretion to vary the order of proof and admit it as part of the case in chief at the rebuttal stage in order to meet the requirements of a particular case, so long as this action does not impair the ability of the defendant to answer and otherwise receive a fair trial.”
2 later decisions quote this exact passage · from the majority“[Huffington] spoke with Hudson at the Golden Forty [a nightclub where Hudson worked as a disc jockey] and arranged to make a cocaine purchase after the bar closed. On leaving the club, they [Kanaras and Huffington] followed Hudson and company to the camp ground [in Kanaras’s car], stopping at the 7-11 on the way. At the trailer, [Huffington] spoke with Hudson about purchasing 3 1/2 grams of cocaine, and about arranging a subsequent deal for the remainder of Hudson’s cocaine. [Huffington] purchased the 3 1/2 grams for $275, toward which Kanaras contributed $100. [Huffington] agreed to try to arrange a deal for the remainder of Hudson’s cocaine, approximately another 3 1/2 grams, at a price of $350. Kanaras and [Huffington] then left the trailer and went to [Huffington’s] apartment, arriving at about 3:30 a.m. At the apartment, Kanaras sat in the living room while [Huffington] went to the bedroom to make some telephone calls. [Huffington] subsequently returned and indicated that he had arranged a purchase. They returned to the campground where[Huffington] told Hudson he had a purchaser and also wanted to discuss a bigger deal later that evening. Hudson then got dressed and left a note on a counter in the trailer whereupon the three men left in Kanaras’s car. [Huffington] gave directions to Wheel Road and instructed Kanaras to park the car in the driveway of an old farm. All three men got out of the car and walked up the driveway, Kanaras and Hudson walking side by side, [Huffin”
1 later decision quote this exact passage · from the majoritye.g. Huffington v. Nuth
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.