State v. Sahr’s Empirical Analysis
1991
Citation profile
16 state decisions
How this case has been cited
Cited by 17 later decisions — most recently October 2025
16 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 Roe v. Wade · Planned Parenthood of Central Missouri v. Danforth · Webster v. Reproductive Health Services · Peer International Corp. v. Pausa Records, Inc. · United States v. Consuelo-Gonzalez
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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““As a result, we conclude that we need not determine the precise scope of the necessity defense available in this state. In our view, the defendants’ criminal trespasses at medical clinics to prevent legal abortions may not be justified under any reasonable formulation of the necessity defense. “The evil, harm, or injury sought to be avoided, or the interest sought to be promoted, by the commission of a crime must be legally cognizable to be justified as necessity. ‘[I]n most cases of civil disobedience a lesser evils defense will be barred. This is because as long as the laws or policies being protested have been lawfully adopted, they are conclusive evidence of the community’s view on the issue.’ 2 P. Robinson, Criminal Law Defenses § 124(d)(1), at 52. Abortion in the first trimester of pregnancy is not a legally recognized harm, and, therefore, prevention of abortion is not a legally recognized interest to promote. “The element of a legally cognizable injury for the necessity defense has been identified repeatedly in decisions on other criminal attempts to protest abortions at medical clinics. ... In sum, a claim of necessity cannot be used to justify a crime that simply interferes with another person’s right to lawful activity.” 470 N.W.2d at 191-192 .”
2 later decisions quote this exact passage“The conditions of probation must be such as the court in its discretion deems reasonably necessary to ensure that the defendant will lead a law-abiding life or to assist the defendant to do so.”
1 later decision quote this exact passage · from the concurrencee.g. State v. Wilder“[p]robationers `properly are subject to limitations from which ordinary persons are free.'”
1 later decision quote this exact passage · from the concurrencee.g. State v. Aune
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.