Erdman v. State’s Empirical Analysis
1993
Citation profile
71 state decisions
How this case has been cited
Cited by 71 later decisions — most recently July 2018 · most notably Wilson v. State (2010), Trousdale v. Henry (2008)
71 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 Bumper v. North Carolina · Montgomery v. State · Cantu v. State · McCambridge v. State · McCullough 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 71 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[n]o evidence obtained by an officer or other person in violation of any provisions of the Constitution or laws of the State of Texas, or of the Constitution or laws of the United States of America, shall be admitted in evidence against the accused on the trial of any criminal case.”
2 later decisions quote this exact passage“[Erdman] consented to the intoxilyzer test only after the trooper gave him warnings, both contemplated and not contemplated by [the implied consent statute], concerning the consequences of refusal. The non-statutory information conveyed to [Erdman] (that he would be jailed and charged with D.W.I.) was of the type that would normally result in considerable psychological pressure upon a D.W.I. suspect to consent to the taking of a breath sample. Given the complete absence of any record evidence showing that this non-statutory information given to [Erdman] had no bearing on his decision to consent, no rational factfinder could conclude that the State carried its burden of showing that [Erd-man’s] consent was voluntary.”
1 later decision quote this exact passagee.g. Sandoval v. State“[A] person [arrested for DWI] must be warned that two specific consequences— only two — will definitely and directly result from a refusal to submit to a breath test.... The Legislature has provided that only these two sanctions will directly result from a refusal to submit to a breath test.... If law enforcement officials were permitted to “warn” D.W.I. suspects — even correctly — that a refusal to submit would result in consequences not contemplated by [the implied consent statute], then suspects could easily be coerced into submission, and the protection afforded by this statutory section would be undermined.”
1 later decision quote this exact passagee.g. Sandoval 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.