State v. Huertas’s Empirical Analysis
1990
Citation profile
3 federal appellate · 225 state decisions
How this case has been cited
Cited by 234 later decisions (2 by the Supreme Court) — most recently September 2025 · most notably Payne v. Tennessee (1991), State v. Smith (1997)
3 federal appellate · 225 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 Wainwright v. Witt · Enmund v. Florida · Press-Enterprise Company v. Superior Court of California Riverside County · Lockhart v. McCree · Booth v. Maryland
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 234 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““To be admissible under Evid.R. 803(2) as an excited utterance, a statement must concern ‘some occurrence startling enough to produce a nervous excitement in the declarant,’ which occurrence the declarant had an opportunity to observe, and must be made ‘before there had been time for such nervous excitement to lose a domination over his reflective faculties. * * * ’ Potter v. Baker (1955), 162 Ohio St. 488 , 55 O.O. 389 , 124 N.E.2d 140 , paragraph two of the syllabus.””
11 later decisions quote this exact passage · from the dissente.g. State v. Johnson · State v. Johnson“[e]xpressions of opinion by a witness as to the appropriateness of a particular sentence in a capital case violate the defendant's constitutional right to have the sentencing decision made by the jury and judge.”
3 later decisions quote this exact passage · from the dissent“The `diminished capacity' defense has been defined by one commentator as arising when `a sane defendant's mental abnormality at the time of the crime prevented him from entertaining the specific mental state prescribed by statute. * * *' Arenella, The Diminished Capacity and Diminished Responsibility Defenses: Two Children of a Doomed Marriage (1977), 77 Colum.L.Rev. 827, 828. If asserted successfully in a jurisdiction where it is recognized, it `results in the reduction of the offense to one with a lesser maximum penalty which does not require proof of the specific intent at issue.' Id. at 829. For a more complete discussion of the diminished capacity defense, see Wilcox, supra, at 184-199 , 24 O.O.3d at 286-294, 436 N.E.2d at 525-533 .”
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.