Frink v. State’s Empirical Analysis
1979
Citation profile
90 state decisions
How this case has been cited
Cited by 90 later decisions — most recently January 2025 · most notably State v. Couture (1984), Mallott v. State (1980)
90 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 Miranda v. State of Arizona Vignera · Brady v. State of Maryland · Katz v. United States · Schneckloth v. Bustamonte · United States v. Agurs
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 90 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he prosecutor’s obligation to present exculpatory evidence to the grand jury does not turn the prosecutor into a defense attorney; the prosecutor does not have to develop evidence for the defendant and present every lead possibly favorable to the defendant.”
9 later decisions quote this exact passage“'Except [for three limited exceptions], hearsay evidence shall not be presented to the grand jury absent compelling justification for its introduction.”
7 later decisions quote this exact passagee.g. Gaona v. State · Nelson v. State“A requirement that the prosecutor present exculpatory evidence to the grand jury is implicit in the mandate of Criminal Rule 6(q). The grand jury cannot be expected to call for evidence of which it is kept ignorant. The vital function of the grand jury is protection of the innocent against oppression and unjust prosecution. The grand jury cannot fulfill this function unless it hears evidence tending to refute, as well as establish, guilt. It is the prosecutor who mainly presents evidence to the grand jury, and if the prosecutor does not present exculpatory evidence to the grand jury, it probably will not hear such evidence.”
3 later decisions quote this exact passagee.g. Mallott v. State · Bragg 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.