State v. Kendricks’s Empirical Analysis
1994
Citation profile
17 state decisions
How this case has been cited
Cited by 17 later decisions — most recently November 2020
17 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 208 So. 2d 886 - Carr v. State · Carroll v. State · 73 Ill. 2d 192 - People v. Robinson · 28 Ill. 2d 464 - The People v. Damen · Aaron 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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We would certainly prefer to abolish the doctrine in its entirety, given its genesis in the profoundly sexist expectation that female victims of sexual crimes should respond in a prescribed manner or risk losing credibility. Even though psychologists have proved that victims respond to sexual attacks in no prescribed way, abolition of the doctrine would strip the victim of one of the few methods to rebut the expectation of outcry, now deeply rooted in our culture. So until the “presumption” that the victim’s testimony is a fabrication disappears, we must retain the doctrine of “fresh complaint,” at least as we have today modified it.”
1 later decision quote this exact passagee.g. State v. Livingston“Because juries were allowed — sometimes even instructed — to draw negative inferences from the [victim’s] failure to complain after an assault [citation omitted], the doctrine of ‘fresh complaint’ evolved as a means of counterbalancing these negative inferences. Used in this way, the ‘fresh complaint’ doctrine allowed the prosecutor to introduce, during the case in chief, evidence that the victim had complained soon after the rape. Its use thereby forestalled the inference that the victim’s silence was inconsistent with her present formal complaint of rape.”
1 later decision quote this exact passagee.g. State v. Speck
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.