State v. Milner’s Empirical Analysis
1997
Citation profile
19 state decisions
How this case has been cited
Cited by 20 later decisions — most recently December 2021
19 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 18 U.S.C. § 871 (Presidential Threat Protection Act of 2000)
Relies on Buckley v. Valeo · Broadrick v. Oklahoma · Kolender v. Lawson · Cantwell v. State of Connecticut · Dombrowski v. Pfister
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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“relie[d] on our decision in Fratzke , in which we held the State could not constitutionally punish an individual for criticizing the conduct of a state trooper, even when that criticism was offensive. In Fratzke , we concluded the defendant’s statements were not “fighting words,” but protected criticism of -the government. In relying on Fratzke , Milner overlooked] that the statements of dissatisfaction made in that case contained no fighting words or threats. In contrast, Milner’s statements were not mere expressions of dissatisfaction with government employees; they were, as the trial court found, threats to place an explosive device in or near the DES building. Milner’s statements transcended mere criticism and threatened the personal safety of the DES employees.”
1 later decision quote this exact passagee.g. State v. Button“Any person who threatens to place or attempts to place any incendiary or explosive device or material, or any destructive substance or device in any place where it will endanger persons or property, commits a class “D” felony.”
1 later decision quote this exact passage“protecting individuals from the fear of violence, from the disruption that fear engenders, and from the possibility that the threatened violence will occur.”
1 later decision quote this exact passagee.g. State v. Perkins
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.