Goldsmith v. State’s Empirical Analysis
1995
Citation profile
2 federal appellate · 72 state decisions
How this case has been cited
Cited by 76 later decisions — most recently May 2023 · most notably Ball v. State (1997), Grandison v. State (1995)
2 federal appellate · 72 state decisions — followed in 12 states
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
Applies 18 U.S.C. § 3500
Relies on Brady v. State of Maryland · United States v. Agurs · Davis v. Alaska · Pennsylvania v. Ritchie · Weatherford v. Bursey
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 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a defendant must establish a reasonable likelihood that the privileged records contain exculpatory information necessary for a proper defense”
4 later decisions quote this exact passage“[t]he mere assertion that the records in question may contain evidence useful for impeachment is insufficient to override an absolute statutory privilege, even at the trial stage---- We cannot permit a privilege to be abrogated even at the trial stage by the mere assertion that privileged records may contain information relevant to credibility. To do so would virtually destroy the psychotherapist-patient privilege of crime victims. It has long been recognized that privileges, by their very nature, restrict access to information which would otherwise be disclosed. The rationale for this restriction has been our recognition of the social importance of protecting the privacy encompassed by specified relationships. Such privacy interests cannot be negated by the mere assertion of the possibility of impeachment evidence.”
3 later decisions quote this exact passage“[C]ourts have used a variety of terms to articulate the appropriate standard. These formulations vary in what the defendant must seek to show, and how persuasively the defendant must show it, in order to trigger the in camera review by the court. How is one to rank, in difficulty of proof, "a reasonable ground to believe,” "a reasonable probability,” "a reasonable belief,” "a reasonable likelihood,” "a good-faith belief, grounded on some demonstrable fact,” and "reasonable certainty”? How is one to compare "would likely impair his right to impeach the witness,” "material information necessary to [the] defense,” "information ... relevant and material to the issue before the court,” "evidence favorable to the accused and material to guilt or punishment, including impeachment evidence,” “exculpatory information necessary for a proper defense,” "exculpatory evidence which is relevant and material to the issue of the defendant’s guilt,” i.e., "material information necessary to the defense,” "exculpatory evidence ... which would be favorable to [the] defense” (is there any other kind of "exculpatory evidence”?), and "necessary to a determination of guilt or innocence”? (Footnotes omitted.)”
2 later decisions quote this exact passage
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.