State v. Clark’s Empirical Analysis
1988
Citation profile
3 federal appellate · 378 state decisions
How this case has been cited
Cited by 383 later decisions (2 by the Supreme Court) — most recently March 2026 · most notably State v. Lott (1990), State v. Mills (1992)
3 federal appellate · 378 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 Edwards v. Arizona · Jackson v. Denno · Colorado v. Connelly · Massiah v. United States · Kirby v. Illinois
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 383 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he record must affirmatively indicate the absence of [the] defendant or his counsel during a particular stage of the trial,”
3 later decisions quote this exact passage · from the majority“'[P]olice overreaching' is a prerequisite to a finding of involuntariness.”
3 later decisions quote this exact passage · from the majoritye.g. State v. Mathews · State v. A.P.““The only reported Ohio case on point has followed the majority rule and permitted the replaying of a videotape exhibit during jury deliberations. ‘It is common practice to send exhibits admitted into evidence into the jury room. * * * Once in the jury room, the exhibits may be examined by the jury to any extent it desires. * * * We find no prejudicial error in the jury’s viewing a second time an exhibit properly admitted into evidence.’ State v. Fellows (1975), 47 Ohio App.2d 154, 158-159 , 1 O.O.3d 249, 252 , 352 N.E.2d 631, 635 .” State v. Clark (1988), 38 Ohio St.3d 252, 257 , 527 N.E.2d 844, 851 ; Trenton v. White Consol. Industries (Dec. 17, 1993), Lake App. No. 92-L-058, unreported, 1993 WL 548453 .”
2 later decisions quote this exact passage · from the majority
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.