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← 43 Wash. App. 605 - State v. Frey

43 Wash. App. 605 - State v. Frey’s Empirical Analysis

1986

Citation profile

28
cited by 28 later decisions
1
states following
August 2009
most recently cited

28 state decisions

How this case has been cited

Cited by 28 later decisions — most recently August 2009 · most notably 114 Wash. 2d 613 - State v. Swan (1990), 94 Wash. App. 80 - State v. Karpenski (1999)

28 state decisions

130198619902000decided

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 Ohio v. Roberts · Dutton v. Evans · 103 Wash. 2d 165 - State v. Ryan · Huff v. White Motor Corp. · United States v. Alvarez

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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “"Admissibility of child's statement — Conditions. A statement made by a child when under the age of ten describing any act of sexual contact performed with or on the child by another, not otherwise admissible by statute or court rule, is admissible in evidence in . . . criminal proceedings in the courts of the state of Washington if: "(1) The court finds, in a hearing conducted outside the presence of the jury, that the time, content, and circumstances of the statement provide sufficient indicia of reliability; and "(2) The child either: "(a) Testifies at the proceedings; or ” (b) Is unavailable as a witness: Provided, That when the child is unavailable as a witness, such statement may be admitted only if there is corroborative evidence of the act."”
    5 later decisions quote this exact passage
  2. “(1) whether there is an apparent motive to lie; (2) the general character of the declarant; (3) whether more than one person heard the statements; (4) whether the statements were made spontaneously; and (5) the timing of the declaration and the relationship between the declarant and the witness.”
    3 later decisions quote this exact passage
  3. “A young child is unlikely to fabricate a graphic account of sexual activity because such activity is beyond the realm of [her] experience.”
    3 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.