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OpenJurist
← 62 OHIOST3D 521 - State v. Xie

State v. Xie’s Empirical Analysis

1992

Citation profile

2,101
cited by 2,101 later decisions
2
states following
March 2026
most recently cited

1 federal appellate · 2,098 state decisions

How this case has been cited

Cited by 2,101 later decisions — most recently March 2026 · most notably State v. Ketterer (2010), State v. Simpkins (2008)

1 federal appellate · 2,098 state decisions

95901992200020102020decided

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 Strickland v. Washington · North Carolina v. Alford · Hill v. Lockhart · State v. Adams · State v. Smith

Cited together with Strickland v. Washington · State v. Smith · 68 Ohio App. 2d 211 - State v. Peterseim · Hill v. Lockhart · 104 Ohio App. 3d 236 - State v. Fish

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 2,101 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[a] defendant does not have an absolute right to withdraw a guilty plea prior to sentencing.”
    175 later decisions quote this exact passage
  2. “A motion to withdraw a plea of guilty or no contest may be made only before sentence is imposed; but to correct manifest injustice the court after sentence may set aside the judgment of conviction and permit the defendant to withdraw his or her plea.”
    146 later decisions quote this exact passage
  3. “[o]ne who enters a guilty plea has no right to withdraw it.”
    58 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.