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← 485 NW2D 911 - State v. Edwards

State v. Edwards’s Empirical Analysis

1992

Citation profile

18
cited by 18 later decisions
2
states following
September 2012
most recently cited

18 state decisions

How this case has been cited

Cited by 18 later decisions — most recently September 2012

18 state decisions

120199220002010decided

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 Idaho v. Wright · Halas v. Department of Energy · Perry v. Louisiana · GAF Corp. v. United States · State v. Joon Kyu Kim

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

  1. “These circumstances [surrounding the making of the statements] include, but are not limited to, whether the statements were spontaneous, whether the person talking with the child had a preconceived idea of what the child should say, whether the statements were in response to leading or suggestive questions, whether the child had any apparent motive to fabricate, and whether the statements are the type of statements one would expect a child of that age to fabricate.”
    2 later decisions quote this exact passage · from the majority
  2. “Applying these factors to the circumstances surrounding complainant’s statements to the sergeant at the hospital, the state argues that the statements are admissible and the defense argues that they are not. * * * There is no indication that the officer had a preconceived notion of what the child should say or that the officer was merely trying to get the child to say what the officer wanted to hear. The child had no apparent motive to fabricate. The statements clearly are not the type of statements one would expect a child of that age to fabricate. Further, the statements not only had an immediately apparent “ring of credibility,” see State v. Larson, 472 N.W.2d [120] at 126, but were internally consistent during the interview.”
    1 later decision quote this exact passage · from the majority
  3. “An out-of-court statement made by a child under the age of ten years * * * alleging, explaining, denying, or describing any act of sexual contact or penetration performed with or on the child * * * not otherwise admissible by statute or rule of evidence is admissible as substantive evidence if: fa) the court * * * finds, in a hearing conducted outside the presence of the jury, that the time, content, and circumstances of the statement and the reliability of the person to whom the statement is made provide sufficient indicia of reliability; and (b) the child * * * ****** (ii) is unavailable as a witness and there is corroborative evidence of the act * * *.”
    1 later decision 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.