Garza v. State’s Empirical Analysis
1982
Citation profile
31 state decisions
How this case has been cited
Cited by 31 later decisions — most recently January 2016 · most notably Matter of M.A.F. (1998), Munroe v. State (1982)
31 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 Heredia v. State · Thompson v. State · Wintters v. State · Stephenson v. State · Rogers v. State
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““New trials, ... shall be granted the defendant for the following causes, and for no other: “(7) Where the jury, after having retired to deliberate upon a case, has received other evidence; .... ””
2 later decisions quote this exact passagee.g. McGary v. State · Stanley v. State““The statute the violation of which is complained of in this case is one which expressly directs that a new trial shall be granted where the jury after retirement receives other testimony. The Constitution guarantees a public trial by an impartial jury and that the accused shall be confronted with the witnesses against him; and one of the provisions of the Code is that one is disqualified as a juror who is a witness in the case. A juror who knows damaging facts against the appellant should disclose them and disqualify himself upon the ground that he is a witness, and failing to do so and disclosing them to the jury after the retirement, can hardly be classified as an impartial juror. The testimony thus received by the jury in its retirement is contrary to the constitutional requirement giving the defendant the right to be confronted with the witnesses against him. Testimony thus received is under circumstances denying the right of cross-examination declared by our courts as an efficacious test for the discovery of truth.... The statutes mentioned were passed to preserve to parties accused of crime the constitutional rights referred to and to protect the state against a corrupt verdict. The inhibition against the receipt by the jury of evidence after its retirement is against legal evidence as well as illegal evidence only. If on the trial of the case the state had proved over the objection of appellant the prior conviction, it would have given its sanction to the introduction”
1 later decision quote this exact passagee.g. Munroe v. State“had a bad criminal record, that he had killed a man, was a murderer, should be put away, and should be locked up.”
1 later decision quote this exact passagee.g. Matter of MAF
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.