State v. Downs’s Empirical Analysis
1977
Citation profile
6 federal appellate · 146 state decisions
How this case has been cited
Cited by 156 later decisions (2 by the Supreme Court) — most recently February 2026 · most notably State v. Unger (1981), State v. Richey (1992)
6 federal appellate · 146 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 In the Matter of Samuel Winship · Gideon v. Wainwright · Mapp v. Ohio · Mullaney v. Wilbur · Williams v. People of State of New York
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 156 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The provisions of R. C. 2929.03(E) that ‘if the court finds * * * that none of the mitigating circumstances listed in division (B) of Section 2929.04 of the Revised Code is established by a preponderance of the evidence, it shall impose the sentence of death on the offender,’ require that the defendant bear the risk of nonpersuasion during the mitigation hearing, but does not impose an unconstitutional burden upon a defendant which would render the Ohio statutory framework for the imposition of capital punishment unconstitutional.””
1 later decision quote this exact passage · from the dissente.g. State v. Nabozny““The proceeding established in R. C. 2929.03 and 2929.04 for imposing sentence for a capital offense is not. an adversary proceeding and, under the provisions of R. 0. 2929.03(1)) and (E), and R. C. 2929.04(B), neither the defendant nor the prosecution is required by statute to offer testimony or other evidence of mitigating circumstances.””
1 later decision quote this exact passagee.g. State v. Faulkner“[t]he failure to return a search warrant to the properly designated judge and to prepare an inventory pursuant to Crim. R. 41(D) and (E) does not render inadmissible the evidence seized pursuant to the warrant.”
1 later decision quote this exact passage · from the dissent
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.