State v. Duncan’s Empirical Analysis
1978
Citation profile
2 federal appellate · 203 state decisions
How this case has been cited
Cited by 205 later decisions — most recently December 2025 · most notably State v. Price (1979), State v. Taylor (1993)
2 federal appellate · 203 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 Beausoliel v. United States · Soto v. Territory of Arizona · 81 Ohio App. 375 - Hill v. Skinner · State v. McFall
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 205 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A]s a general rule, when an oral utterance is made while the exciting event is still in progress courts have little difficulty in invoking the spontaneous exclamation exception to the hearsay rule, but as the time between the event and the statement increases, so does the reluctance to find the statement an excited utterance. * * * Nevertheless, in our opinion each case must be decided on its own circumstances, since it is patently futile to attempt to formulate an inelastic rule delimiting the time limits within which an oral utterance must be made in order that it be termed a spontaneous exclamation.”
6 later decisions quote this exact passage“each case must be decided on its own circumstances, since it is patently futile to attempt to formulate an inelastic rule delimiting the time limits within which an oral utterance must be made in order that it be termed a spontaneous exclamation.”
4 later decisions quote this exact passage“* * * an appellate court should allow a wide discretion in the trial court to determine whether in fact a declarant was at the time of an offered statement still under the influence of an exciting event.”
3 later decisions quote this exact passage
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.