Gaines v. State’s Empirical Analysis
2000
Citation profile
133 state decisions
How this case has been cited
Cited by 133 later decisions — most recently March 2026 · most notably Ferguson v. State (2000), Walley v. State (2003)
133 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 Scarborough v. Fischer · Nooner v. State · Echols v. State · Misskelley v. State · McGhee 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 133 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he general rule is that evidence of other crimes by the accused, not charged in the indictment or information and not a part of the same transaction, is not admissible at the trial of the accused; however, evidence of other crimes is admissible under the res gestae exception to the general rule to establish the facts and circumstances surrounding the alleged commission of the offense. Haynes v. State, 309 Ark. 583 , 832 S.W.2d 479 (1992); Young v. State, 269 Ark. 12 , 598 S.W.2d 74 (1980). Under the res gestae exception, the State is entitled to introduce evidence showing all circumstances which explain the charged act, show a motive for acting, or illustrate the accused’s state of mind if other criminal offenses are brought to light. Haynes v. State, supra. Specifically, all of the circumstances connected with a particular crime may be shown to put the jury in possession of the entire transaction. Haynes v. State, supra. Where separate incidents comprise one continuing criminal episode or an overall criminal transaction, or are intermingled with the crime actually charged, the evidence is admissible. See Ruiz & Van Denton v. State, 265 Ark. 875 , 582 S.W.2d 915 (1989); Thomas v. State, 273 Ark. 50 , 615 S.W.2d 361 (1981); Henderson v. State, 284 Ark. 493 , 684 S.W.2d 231 (1985). Res gestae testimony and evidence is presumptively admissible. Henderson, supra; Lair v. State, 283 Ark. 237 , 675 S.W.2d 361 (1984); Love v. State, 281 Ark. 379 , 664 S.W.2d 457 (1984); Hobbs v. ”
3 later decisions quote this exact passage“Evidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show that he acted in conformity therewith. It may, however, be admissible for other purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.”
3 later decisions quote this exact passage“A mistrial is a drastic remedy and should be declared only when there has been an error so prejudicial that justice cannot be served by continuing the trial, or when the fundamental fairness of the trial itself has been manifestly affected. The trial court has wide discretion in granting or denying a motion for a mistrial, and absent an abuse of that discretion, the trial court’s decision will not be disturbed on appeal. [Citations omitted.]”
1 later decision quote this exact passagee.g. Lawson 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.