State v. JCE’s Empirical Analysis
1988
Citation profile
38 state decisions
How this case has been cited
Cited by 38 later decisions — most recently September 2024 · most notably State v. Apodaca (1994), State v. Arlington (1994)
38 state decisions — followed in 10 states
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 103 Wash. 2d 165 - State v. Ryan · State v. Robinson · Townsend v. State · State v. Geyman · 50 Wis. 2d 702 - Bertrang 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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“1. The victim must be unavailable to testify, whether through incompetency, illness, or some other like reason (e.g., trauma induced by the courtroom setting); 2. The proffered hearsay must be evidence of a material fact, and must be more probative than any other evidence available through reasonable means; and 3. The party intending to offer the hearsay testimony must give advance notice of that intention.”
6 later decisions quote this exact passagee.g. Matter of ADB · State v. Harris“circumstantial guarantees of trustworthiness.”
6 later decisions quote this exact passagee.g. State v. Harris · State v. Mayes“1. The Attributes of the Child Hearsay Declarant a. The child's age: K.M. was almost three years old when she made the initial statement to her mother. b. The child's ability to communicate verbally: K.M.'s ability to communicate was probably appropriate for her age, but certainly marginal in the scheme of things. c. The child's ability to comprehend the statements or questions of others: Again, age appropriate, but marginal compared to a typical competent witness. d. The child's ability to tell the difference between truth and falsehood: Probably age appropriate, but according to her mother, K.M. is unable to consistently differentiate between fact and fiction. e. The child's motivation to tell the truth (i.e., whether the child understands the general obligation to speak truthfully and not fabricate stories): There is no reason to believe that K.M. does not love her father or that she would want him to get in trouble. f. Whether the child possessed sufficient mental capacity at the time of the alleged incident to receive an accurate impression of it: K.M. apparently received an accurate impression of what had happened to her, as evidenced by the fact that the Defendant allegedly admitted doing what K.M. reported. g. Whether the child possesses sufficient memory to retain an independent recollection of the events at issue: K.M. repeated the allegation three weeks after first telling her mother. 2. The Witness Relating the Hearsay Statement. a. The witness's relationship to t”
3 later decisions quote this exact passagee.g. State v. Harris · State v. S.T.M.
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.