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← 67 Haw. 563 - State v. Ikaika

State v. Ikaika’s Empirical Analysis

1985

Citation profile

41
cited by 41 later decisions
1
states following
February 2022
most recently cited

41 state decisions

How this case has been cited

Cited by 41 later decisions — most recently February 2022 · most notably State v. Hoey (1994), State v. Pau'u (1992)

41 state decisions

10019851990200020102020decided

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 · Edwards v. Arizona · Rhode Island v. Innis · Shea v. Louisiana · State v. Santiago

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

  1. “first demonstrate[s] the use of procedural safeguards effective to secure the privilege against self-incrimination.”
    2 later decisions quote this exact passage · from the majority
  2. “focuses primarily upon the perceptions of the suspect, rather than the intent of the police”
    2 later decisions quote this exact passage · from the majority
  3. “Lieutenant Bartolomé was unaware of the circumstances of the Defendant’s detention and did not initiate any questioning until Defendant approached him. His resulting remarks were intended merely as a greeting. Bartolomé asked no further questions and made no other remarks. Moreover, the Defendant had had previous encounters with law enforcement. He had been arrested, booked and processed for prior offenses and had been advised of his constitutional rights at least twice before. The Defendant had been jailed on an unrelated misdemeanor in April 1981. At that time, he was advised of his Miranda rights by his attorney who specifically informed him that “loose lips sink ships” referring to the inadvisability of speaking to police without an attorney present. Under these facts, we are unable to conclude that Lieutenant Bartolomé could have or should have reasonably foreseen that his words or actions would elicit an incriminating response from the Defendant. At most, Bartolomé could have expected that the Defendant respond to his pleasantry by informing him of the reasons for the Defendant’s being booked and the case he was involved in. The Defendant’s confession was of the nature of an unsolicited, spontaneous statement made in the absence of any police questioning. Neither are we persuaded that the combined conduct of the police officers reveals a pattern of coercion sufficient to constitute interrogation. Accordingly, the Defendant’s constitutional rights under both the United S”
    1 later decision quote this exact passage · from the majority

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.