Giles v. California’s Empirical Analysis
2008
Citation profile
88 federal appellate · 5 district · 563 state decisions
How this case has been cited
Cited by 798 later decisions (21 by the Supreme Court) — most recently December 2025 · most notably Melendez-Diaz v. Massachusetts (2009), Michigan v. Bryant (2011)
88 federal appellate · 5 district · 563 state decisions — followed in 40 states
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.
Appellate journey
reviewedthe decision below (from California Supreme Court)
Relationships
Relies on Crawford v. Washington · Ohio v. Roberts · Allen v. United States · Bourjaily v. United States · Davis v. Washington
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 798 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“one who obtains the absence of a witness by wrongdoing forfeits the constitutional right to confrontation.”
39 later decisions quote this exact passage · from the concurrence“[t]he manner in which the [forfeiture by wrongdoing doctrine] was [historically] applied makes plain that unconfronted testimony would not be admitted without a showing that the defendant intended to prevent a witness from testifying. In cases where the evidence suggested that the defendant had caused a person to be absent, but had not done so to prevent the person from testifying -- as in the typical murder case involving accusatorial statements by the victim -- the testimony was excluded unless it was confronted or fell within the dying-declarations exception. Prosecutors do not appear to have even argued that the judge could admit the unconfronted statements because the defendant committed the murder for which he was on trial.”
10 later decisions quote this exact passage · from the majority“[w]e have previously acknowledged that two forms of testimonial statements were admitted at common law even though they were unconfronted. The first of these were declarations made by a speaker who was both on the brink of death and aware that he was dying. . . . A second common-law doctrine, which we will refer to as forfeiture by wrongdoing, permitted the introduction of statements of a witness who was “detained” or “kept away” by the “means or procurement” of the defendant.”
8 later decisions 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.