Watson v. State’s Empirical Analysis

Citation profile

4 federal appellate · 1 district · 40 state decisions

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

1. “In Watson , we concluded the court of appeals erred because it assumed the appellant had to verbally and specifically assert his right to remain silent before police had to scrupulously honor his decision to remain silent: "There need not be a formal invocation of constitutional or Miranda rights. Anything said or done by the defendant that could reasonably be interpreted as a desire to invoke these rights should be sufficient to halt questioning.” Id. at 598. As such, the court of appeals should have applied the Mosley test. In light of the fact that the appellant made it clear he wished to remain silent, police did not stop questioning, police interrogated the appellant four times in the same day, the interrogations were separated by a few hours, and the same police interrogated the appellant regarding the same crime, we held police did not scrupulously honor the appellant’s right to remain silent. Finally, we noted the totality of the circumstances did not demonstrate that the appellant knowingly, intelligently, and voluntarily waived his right. The present case presents completely different facts and a different legal inquiry. Watson does not support Appellant’s contention that she is entitled to relief. Instead, it stands for the proposition that each case must be analyzed based on its own facts and circumstances.”

   1 later decision quote this exact passage
   e.g. Maestas v. State

2. “A: Where is he? Q: Did you understand what I just said? A: No, I’m saying where is he? Q: Where is who? A: My lawyer. Q: I haven’t asked you any questions yet. A: Yes, you did. Q: No, I haven’t. A: Yes, sir. Where is my lawyer? Where is he? I don’t see him standing here? Q: If you are unable to employ one, one will be appointed for you. Do you understand? A: I’m not answering any questions. Q: I don’t care. A: I don’t care either. Where is he? You stated “my lawyer_” Where is he?_ Q: Are you done now? A: I’m done. Are you done? Q: I will be in a minute. A: I’ve been polite to you .... good night. Q: You have the right to terminate the interview at any time ... A: I terminate it. Good night. Q: Do you understand these rights? A: No, I don’t. About three of them. Q: Which ones? A: I terminate. Good night Q: Which ones didn’t you understand? A: Good night.... I didn’t do anything wrong. Q: I didn’t arrest you. You don’t have to prove anything to me. A: Not to you. Good night- I didn’t do anything wrong with you or with those people. Q: Which rights did you not understand. Could you clarify? A: I’m not clarifying. Q: So, did you understand all of them? A: No. Good night. I’m not understanding anything until my lawyer is present. Q: All right. It’s terminated. 4”

   1 later decision quote this exact passage · from the concurrence
   e.g. Cooper v. State