Garroutte v. State’s Empirical Analysis
1984
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently May 2007
14 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 Chambers v. Mississippi · Commissioner v. Engle · Joseph Skilken & Co. v. City of Toledo · Washington Post Co. v. Rebozo · United States v. Marathon Pipe Line Co.
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Garroutte separately argues that exclusion of Snyder’s statement violated his constitutional right to due process of law. He relies on Chambers v. Mississippi, 410 U.S. 284 , 93 S.Ct. 1038 , 35 L.Ed.2d 297 (1973). In Chambers , the United States Supreme Court held that the due process clause was violated by mechanical , application of a state law excluding statements against penal interest. The court reversed the defendant’s conviction because he had been precluded from admitting an out-of-court statement that “afforded persuasive assurances of trustworthiness” and was “well within the basic rationale of the exception for declarations against interest.” Chambers, 410 U.S. at 302 , 93 S.Ct. at 1049 , 35 L.Ed.2d at 313 . [But the] standards of admissibility prescribed by Evidence Rule 804(b)(3) parallel the constitutional mandate of Chambers . ... Our holding that Snyder’s statement was not clearly corroborated therefore controls Garroutte’s constitutional claim.”
1 later decision quote this exact passagee.g. Cleveland v. State“(b) Hearsay Exceptions. The following are not excluded by the hearsay rule if the declarant is unavailable as a witness: [[Image here]] (3) Statement Against Interest. A statement which was at the time of its making so far contrary to the declarant’s pecuniary or proprietary interest, or so far tended to subject him to civil or criminal liability, or to render invalid a claim by him against another, that a reasonable man in his position would not have made the statement unless he believed it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.”
1 later decision quote this exact passagee.g. Bright v. State“(a) For purposes of considering prior convictions in imposing sentence under this chapter (2) a conviction in this or another jurisdiction of an offense having elements substantially identical to those of a felony defined as such under Alaska law is considered a prior felony conviction....”
1 later decision quote this exact passagee.g. Harlow 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.