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← 60 Haw. 241 - State v. Bell

State v. Bell’s Empirical Analysis

1978

Citation profile

57
cited by 57 later decisions
5
states following
March 2024
most recently cited

2 district · 55 state decisions

How this case has been cited

Cited by 57 later decisions — most recently March 2024 · most notably State v. Melear (1981), State v. O'DANIEL (1980)

2 district · 55 state decisions

240197819801990200020102020decided

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 Ohio Bureau of Employment Services v. Hodory · United States v. Calandra · Bassett Furniture Industries, Inc. v. Bravman · California v. Southland Royalty Co. · Boykin v. Alabama

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 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “'is an ex parte investigation to determine whether a crime has been committed and whether criminal proceedings should be instituted against any person.'”
    4 later decisions quote this exact passage
  2. “... [A] grand jury proceeding is not adversary in nature. An application of this principle is found in the rule that an indictment may not be attacked on the ground of the incompetency of the evidence considered by the grand jury, where proseeutori al misconduct is not involved. State v. Layton, 53 Haw. 513 , 497 P.2d 559 (1972); United States v. Calandra, 414 U.S. 338 , 94 S.Ct. 613 , 38 L.Ed.2d 561 (1974). The function of a grand jury to protect against unwarranted prosecution does not entail a duty to weigh the prosecution’s case against that of the defense, or even to determine that the prosecution’s case is supported by competent evidence. On the other hand, an indictment that is the result of prosecutorial misconduct or other circumstances which prevent the exercise of fairness and impartiality by the grand jury may be successfully attacked. State v. Joao, 53 Haw. 226, 491 P.2d 1089 (1971);[ 3 ] State v. Pacific Concrete and Rock Co., 57 Haw. 574 , 560 P.2d 1309 (1977).”
    3 later decisions quote this exact passage · from the concurrence
  3. “[t]o require the prosecutor to present any and all information which may have a tendency to exculpate the accused would, in our view, confer upon grand jury proceedings the adversary nature which is more properly reserved for the actual trial phase of prosecution.”
    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.