State v. Anders’s Empirical Analysis
1998
Citation profile
12
cited by 12 later decisions
1
states following
June 2010
most recently cited
12 state decisions
Relationships
Relies on Soberon v. United States · Needler v. Valley National Bank of Arizona · State v. Sullivan · United States v. Pallais · United States v. Posner
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We agree with the Court of Appeals’ holding that Simmons’ admission to the crime in no way furthered the conspiracy. Accord United States v. Posner, 764 F.2d 1535 (11th Cir. 1985), cert. denied (although statements made to “allay suspicions” may be “in furtherance” of conspiracy, “spilling the beans” does not further conspiracy); United States v. Pallais, 921 F.2d 684 (7th Cir.1990), cert. denied, 502 U.S. 842 , 112 S.Ct. 134 , 116 L.Ed.2d 101 (1991) (casual admissions of culpability are not “in furtherance” of conspiracy and are insufficiently reliable to be considered by the jury). Accordingly, the Court of Appeals correctly ruled the statement was not admissible under the co-conspirator exception. See State v. Sullivan, 277 S.C. 35, 42 , 282 S.E.2d 838, 842 (1981) (exception to rule against hearsay permits statements of one conspirator made during the pendency of the conspiracy, and in furtherance thereof, to be admitted against a co-conspirator once prima facie evidence of a conspiracy is proved); see also South Carolina Rules of Evidence, Rule 801(d)(2)(E).”
1 later decision quote this exact passagee.g. State v. Sims“Rule 801(d)(2) provides a statement is an admission if it is “offered against a party and is (A) the party’s own statement in either an individual or a representative capacity ...” The statement here was not Anders’ “own statement,” and was clearly therefore not admissible as an admission against Anders.”
1 later decision quote this exact passage“even if made during the conspiracy, the statement in no way advanced the conspiracy.”
1 later decision quote this exact passagee.g. State v. Sims
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.