35 Ala. App. 187 - Helms v. State’s Empirical Analysis
1950
Citation profile
17 state decisions
How this case has been cited
Cited by 19 later decisions — most recently August 2005
17 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 Carlisle v. Killebrew · 34 Ala. App. 82 - Helms v. State · Britton v. State · 30 Ala. App. 229 - Roden Son v. State · 34 Ala. App. 52 - Russell 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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"[I]t is clearly settled by the doctrines of our cases that a judgment gained in a civil suit is not admissible against the defendant in a criminal prosecution growing out of the same transaction. Britton v. State, 77 Ala. 202 . Conversely, verdicts in criminal cases are not admissible in civil cases arising out of the same transactions. Carlisle v. Killebrew, 89 Ala. 329 , 6 So. 756 , 6 L.R.A. 617 . "In Roden and Son v. State, 30 Ala. App. 229 , 3 So.2d 420, 421 , Justice Simpson stated that: `A judgment in a civil case is not conclusive as res judicata in a criminal case, or vice versa, there being no mutuality of parties and a different degree of proof, respectively, being required.' "In 22 C.J.S., Criminal Law, § 50, the general rule, amply supported by authority, is states as follows: "* * * it is generally held that a judgment or opinion in a civil action, or the record of proceedings therein, is not admissible in a subsequent criminal prosecution involving the same matter.'”
4 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.