State v. Hannagan’s Empirical Analysis
1977
Citation profile
35 state decisions
How this case has been cited
Cited by 37 later decisions (1 by the Supreme Court) — most recently December 2017 · most notably Smith v. Doe (2003), Braham v. State (1977)
35 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
Applies 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Chapman v. State of California · Illinois v. Allen · Snyder v. Commonwealth of Massachusetts · Hopt v. People of the Territory of Utah · Lewis v. United States
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[the defendant shall be present ... at every stage of the trial”
4 later decisions quote this exact passagee.g. Cox v. State · Osborne v. State“The playback involved no rights to confront witnesses or cross-examine witnesses and was not a situation in which polling of the jury would be appropriate. The reason the jury would be appropriate. In the presence of the jury, counsel for Hannagan attempted to waive Mr. Hannagan’s rights to be present, and the district attorney concurred in this result. The trial court indicated its willingness initially to wait until morning when Mr. Hannagan would be present. Under these circumstances, we believe that it was made sufficiently clear to the jury that Mr. Hannagan had not absconded from the jurisdiction or defied an order of the court to be present so as to create an unfavorable impression to the jury. There is no allegation here that there was communication between the court and the jury without counsel for both sides present. This case does not involve rein-struction of the jury on matters of law. We do not think that the psychological effects of defendant’s absence during a 45-minute replay merits retrial in this case.”
1 later decision quote this exact passagee.g. Dixon v. State“[T]he waiver [of the defendant’s right to be present] is effective only if either: (1) the defendant has given counsel express authority in a knowing and intelligent manner, (2) the defendant is present at the time of the waiver, has clearly been informed of his rights, and remains silent, or (3) the defendant subsequently acquiesces in the proceedings in a knowing and intelligent manner.”
1 later decision quote this exact passagee.g. Peckham v. State
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.