Zinger v. State’s Empirical Analysis
1993
Citation profile
6 federal appellate · 71 state decisions
How this case has been cited
Cited by 80 later decisions — most recently June 2025 · most notably Echols v. State (1996), Burmingham v. State (2000)
6 federal appellate · 71 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 52 Cal. 3d 648 - People v. Kaurish · State v. Wilson · Berry v. State · Henry v. State · Bennett 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 80 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A defendant may introduce evidence tending to show that someone other than the defendant committed the crime charged, but such evidence is inadmissible unless it points directly to the guilt of the third party. Evidence which does no more than create an inference or conjecture as to another’s guilt is inadmissible.”
9 later decisions quote this exact passage“[T]he rule does not require that any evidence, however remote, must be admitted to show a third party’s possible culpability . . . [E]vidence of mere motive or opportunity to commit the crime in another person, without more, will not suffice to raise a reasonable doubt about a defendant’s guilt: there must be direct or circumstantial evidence linking the third person to the actual perpetration of the crime.”
4 later decisions quote this exact passage“To address this issue, we must consider under what circumstances evidence incriminating others is relevant to prove a defendant did not commit the crime charged.... Addressing this precise issue, the Supreme Court of North Carolina stated: A defendant may introduce evidence tending to show that someone other than the defendant committed the crime charged, but such evidence is inadmissible unless it points directly to the guilt of the third party. Evidence which does no more than create an inference or conjecture as to another's guilt is inadmissible. State v. Wilson, 322 N.C. 117 , 367 S.E.2d 589 (1988). The Supreme Court of California has recognized that a defendant has the right to present evidence of third party culpability but stated: [T]he rule does not require that any evidence, however remote, must be admitted to show a third party's possible culpability ... [E]vidence of mere motive or opportunity to commit the crime in another person, without more, will not suffice to raise a reasonable doubt about a defendant's guilt: there must be direct or circumstantial evidence linking the third person to the actual perpetration of the crime. People v. Kaurish , 52 Cal. 3d 648 , 276 Cal. Rptr. 788 , 802 P.2d 278 (1990). Although there are some similarities between the crimes committed in Louisiana and Arkansas, there was no evidence presented connecting the Louisiana suspect to the Holley murder. The Trial Court was not even given the name of the Louisiana suspect or whether he ”
1 later decision quote this exact passagee.g. Barefield v. State
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.