34 Ohio App. 3d 180 - State v. Smith’s Empirical Analysis
1986
Citation profile
42 state decisions
How this case has been cited
Cited by 42 later decisions — most recently September 2025 · most notably State v. Richcreek (2011), 79 Ohio App. 3d 589 - State v. Humphries (1992)
42 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 Angrist v. United States · United States v. Bailey · State v. Edwards · Jordan v. Arizona · State v. Ferguson
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(July 16, 2015 Tr. at 53.) {¶ 80} Furthermore, we find it reasonable for the magistrate and the juvenile court to conclude M.P. made the statements relating to sexual abuse she suffered at the hands of S.M.B. while M.P. was still under the stress of excitement caused by the abuse. C.P.'s testimony about the sudden and disturbing changes in M.P.'s behavior”
3 later decisions quote this exact passage“(2) Excited Utterance. A statement relating to a startling event or condition made while the declarant was under the stress of excitement caused by the event or condition. * * *”
2 later decisions quote this exact passage“"`While it is true that contemporaneity is a factor to be considered in determining the admissibility of such statements, it is by no means controlling, and such things as the nature of the event, the victim's state of mind, and all other circumstances are important considerations. The precise amount of time that may elapse before a statement loses its spontaneity as an excited utterance evoked by a startling event and becomes a mere narrative cannot be established by any absolute rule of law and accordingly, [m]uch must be left to the discretion of the [trial] court in admitting or rejecting such testimony.'" State v. Smith (1986), 34 Ohio App.3d 180 , 190 , quoting State v. Martineau (1974), 114 N.H. 552 , 556-557 (statements made two or three hours after incident).”
1 later decision 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.