4 Wash. 2d 676 - State v. Ingels’s Empirical Analysis
1940
Citation profile
13 state decisions
How this case has been cited
Cited by 13 later decisions — most recently July 2020
13 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 State v. Wappenstein · People v. Ah Bean · Thompson v. People · State v. Guthrie · State ex rel. Murphy v. Superior Court for Whatcom County
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In 3 Wharton’s Criminal Evidence, 11th Ed., 2098, § 1236, the rule is stated as follows: “While the privilege against revealing confidential communications between attorney and client may be waived by the .client, the evidence of the waiver must be distinct and unequivocal. . . . At least, the mere fact that the client, whether he is an ordinary witness in a criminal prosecution or the accused, testifies does not constitute a waiver; nor does the fact that he calls his attorney as a witness without examining him as to such privileged communication. But if the client opens up the subject in his testimony by voluntarily testifying thereto, the privilege is deemed waived. The supreme court of Minnesota, in the case of State v. Tall, 43 Minn. 273 , 45 N.W. 449, 450 , considering the matter of cross-examination of a material witness for the defendant in a criminal action as to whether or not he had communicated to his attorney a fact to which he had testified, used the following language: “The privilege belongs to the client, and not to the attorney, and where the client testifies to the fact in question there can be no reason, in general, why he may not be required to testify as to whether he had communicated that fact to his attorney.””
1 later decision quote this exact passage · from the majoritye.g. Franko v. State“An attorney or counselor shall not, without the consent of his or her client, be examined as to any communication made by the client to him or her, or his or her advice given thereon in the course of professional employment.”
1 later decision quote this exact passage · from the majority“vests ... a wide discretion to be exercised in the matter of excusing persons summoned for jury service from the performance of that duty.”
1 later decision quote this exact passage · from the majoritye.g. State v. Irby
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.