32 Ohio App. 2d 284 - State v. Clifton’s Empirical Analysis
1972
Citation profile
6 federal appellate · 21 state decisions
How this case has been cited
Cited by 34 later decisions (2 by the Supreme Court) — most recently June 2025 · most notably Engle v. Isaac (1982), 10 Ohio App. 3d 56 - State v. Sims (1983)
6 federal appellate · 21 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.
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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[O]ne who kills in self-defense does so without the mens rea that otherwise would render him culpable of the homicide.... However, if A had no criminal intent with respect to B, as where A is exercising a lawful right of self-defense, [no criminal intent] could exist as to C. It follows, then, that A in shooting C has not committed a criminal act, the essential [sic] of a mens rea being impossible of proof. The inquiry must be whether the killing would have been justifiable if the accused had killed the person whom he intended to kill, as the unintended act derives its character from the intended.”
1 later decision quote this exact passagee.g. Jamison v. State“while the defendant had No. 19AP-574 14 his back turned, the elder brother struck him on the shoulder with a belt, the buckle of which left a discernible mark upon the flesh.”
1 later decision quote this exact passagee.g. State v. Vinson“one who kills in self-defense does so without the mens rea that otherwise would render him culpable of the homicide”
1 later decision quote this exact passagee.g. Engle v. Isaac
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.