State v. Easterling’s Empirical Analysis
1980
Citation profile
179 state decisions
How this case has been cited
Cited by 179 later decisions — most recently February 2018 · most notably State v. Young (1985), State v. Stokes (1987)
179 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 Padilla-Martinez v. United States · Pope v. Nebraska · Beal v. Franklin · State v. Johnson · State v. Westbrook
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 179 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) . . . that ... all 12 jurors must agree to a verdict of guilty or not guilty. (b) . . . that: (1) Jurors have a duty to consult with one another and to deliberate with a view to reaching an agreement, if it can be done without violence to individual judgment; (2) Each juror must decide the case for himself, but only after an impartial consideration of the evidence with his fellow jurors; (3) In the course of deliberations, a juror should not hesitate to reexamine his own views and change his opinion if convinced it is erroneous; and (4) No juror should surrender his honest conviction as to the weight or effect of the evidence solely becaue of the opinion of his fellow jurors, or for the mere purpose of returning a verdict.”
11 later decisions quote this exact passage · from the concurrence“All right, now, Members of the Jury, anything further? I presume that you members of the jury realize what a disagreement means. It means, of course, that it will be more time of the Court that will have to be consumed in the trial of this action again. I don’t want to^force you or coerce you in any way to reach a verdict, but it is your duty to try to reconcile your differences and reach a verdict if it can be done without the surrender of one’s conscientious convictions. You’ve heard the evidence in the case. A mistrial, of course, will mean that more time and another jury will have to be selected to hear the ca$es and this evidence again. I realize the fact that there are sometimes reasons why jurors cannot agree. I want to emphasize the fact to you that it is your duty to do whatever you can to reason the matter over together as reasonable men and women and to reconcile your differences if such is possible without surrendering your conscientious convictions and to reach a verdict. I’m going to let you resume your deliberations and see if you can. (Emphasis supplied.)”
3 later decisions quote this exact passage · from the concurrence““We caution the trial bench, however, that our holding today is not to be taken as disapproval of the contrary result reached in State v. Lamb, supra, [ 44 N.C. App. 251 (1980)] a case in which initial jury disagreement preceded the offending instruction. Clear violations of the procedural safeguards contained in G.S. 15A-1235 cannot be lightly tolerated by the appellate division. Indeed, it should be the rule rather than the exception that a disregard of the guidelines established in that statute will require a finding on appeal of prejudicial error.” Id. at 609, 268 S.E.2d at 809-10 .”
3 later decisions quote this exact passage · from the concurrencee.g. State v. Lipfird · State v. Peek
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.