776 So. 2d 418 - State v. Bell’s Empirical Analysis

Citation profile

17 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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[t]he erroneous admission of other crimes evidence is subject to harmless error analysis under the standard set out in Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967). See State v. Gibson, 391 So.2d 421 (La.1980). Under Chapman , an appellate court must decide "whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction," and "the court must be able to declare a belief that [the error] was harmless beyond a reasonable doubt." Chapman, 386 U.S. at 24 , 87 S.Ct. 824 . The Chapman standard was later refined in Sullivan v. Louisiana, 508 U.S. 275, 279 , 113 S.Ct. 2078 , 124 L.Ed.2d 182 (1993), as follows: "Consistent with the jury-trial guarantee, the question [ Chapman ] instructs the reviewing court to consider is not what effect the constitutional error might generally be expected to have upon a reasonable jury, but rather what effect it had upon the guilty verdict in the case at hand.... The inquiry, in other words, is not whether, in a trial that occurred without the error, a guilty verdict would surely have been rendered, but whether the guilty verdict actually rendered in this trial was surely unattributable to the error." (emphasis in original).”

   3 later decisions quote this exact passage
   e.g. 124 So. 3d 1275 - State v. Raines · 965 So. 2d 642 - State v. Delaney

2. “The very purpose of prohibition of the admission of such evidence, as stated in La. Code Evid. art. 404 A, is to prevent the jury's convicting an accused on the basis of evidence that the accused's action in the charged crime was in conformity with his or her prior conduct and the evidence of the prior conduct tends to prove only that the accused was a person of bad character. When the prosecutor, as in the present case, emphasizes to the jury that the charged conduct was characteristic of the accused because he had committed the same crime before, the heavy burden on the prosecution in demonstrating harmless error becomes even more difficult to meet.”

   2 later decisions quote this exact passage
   e.g. State v. Higginbotham · 788 So. 2d 1255 - State v. LeBlanc

3. “whether the reviewing court can conclude, beyond a reasonable doubt, that the verdict rendered by this jury, who did in fact hear the inadmissible evidence, was surely unattributable to that highly prejudicial evidence ...”

   1 later decision quote this exact passage
   e.g. 788 So. 2d 1255 - State v. LeBlanc