State v. Henderson’s Empirical Analysis
1988
Citation profile
342 state decisions
How this case has been cited
Cited by 353 later decisions (2 by the Supreme Court) — most recently March 2026 · most notably State v. Lott (1990), State v. Mills (1992)
342 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 Strickland v. Washington · Darden v. Wainwright · Caldwell v. Mississippi · Ake v. Oklahoma · State v. Adams
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 353 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a] trial jury is presumed to follow the instructions given to it by the judge.”
3 later decisions quote this exact passage“[T]o find attempted rape, the jury only had to find beyond a reasonable doubt that appellant purposely took a substantial step toward committing the rape of [the victim]. State v. Woods, 48 Ohio St.2d 127 , 357 N.E.2d 1059 (1976). “To constitute a substantial step, the conduct must be strongly corroborative of the ... [appellant’s] criminal purpose.” Id. Here, the victim’s body was found nude, with legs spread. Appellant is a type O secretor and semen consistent with such a person was present on the appellant’s coat. Semen was also found in the victim’s vagina. The pattern of blood from injuries inflicted on the victim’s body indicated that most were inflicted while she was in a horizontal position. Her body also had a bloody smear across her right breast. There was also no evidence of theft or any non-sexual crime for appellant’s being in the apartment. Taken together, these facts, as established by circumstantial evidence, meet the Woods test. Circumstantial evidence is sufficient to establish an ele ment of any crime, including attempted rape. State v. Graven, 54 Ohio St.2d 114, 374 N.E.2d 1370, 1373 (1978).”
1 later decision quote this exact passage“In the penalty phase of a capital prosecution, where two or more aggravating circumstances arise from the same act or indivisible course of conduct and are thus duplicative, the duplicative aggravating circumstances will be merged for purposes of sentencing. Should this merging of aggravating circumstances take place upon appellate review of a death sentence, resentencing is not automatically required where the reviewing court independently determines that the remaining aggravating circumstances outweigh the mitigating factors beyond a reasonable doubt and that the jury's consideration of duplicative aggravating circumstances in the penalty phase did not affect the verdict.”
1 later decision quote this exact passagee.g. State v. Williams
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.