State v. Steffes’s Empirical Analysis

Citation profile

54 state decisions

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

1. “Bad faith, as used in cases involving destroyed evidence or statements, means that the state deliberately destroyed the evidence with the intent to deprive the defense of information; that is, that the evidence was destroyed by, or at the direction of, a state agent who intended to thwart the defense.”

   4 later decisions quote this exact passage
   e.g. State v. Thill · State v. Bousum

2. “'Relying upon state constitutional law, some states hold that even in situations where defendants cannot show bad faith on the part of the state in failing to preserve material evidence, defendants may nonetheless be entitled to an adverse-inference instruction, dismissal, or new trial if they can make a sufficient showing of substantial prejudice. These states take authority from Justice Stevens's concurring opinion in Arizona v. Youngblood wherein he wrote:”

   3 later decisions quote this exact passage · from the concurrence
   e.g. 678 So. 2d 1197 - Grimsley v. State · State v. Haibeck

3. ““FAILURE TO PRODUCE EVIDENCE “The state has the duty to preserve all relevant evidence. If the state has failed to offer evidence under their control and the evidence was not equally available to the defendant, you may infer that the evidence would be unfavorable to the state. “NDJI-CIVIL 1625 (modified)””

   2 later decisions quote this exact passage
   e.g. City of Bismarck v. Holden · State v. Ostby