93 Wash. 2d 823 - State v. Cunningham’s Empirical Analysis
1980
Citation profile
134 state decisions
How this case has been cited
Cited by 134 later decisions — most recently March 2025 · most notably State v. Brown (1997), 101 Wash. 2d 664 - State v. Rupe (1984)
134 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 Perini v. Downey · United States v. Turner · 73 Wash. 2d 616 - State v. Martin · 27 Wash. 2d 336 - State v. Britton · 91 Wash. 2d 638 - State v. Wicke
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 134 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“harmless error beyond a reasonable doubt”
21 later decisions quote this exact passage“is specifically aimed at the specialized activity of police taking recorded statements from arrested persons, as distinguished from the general public. While mere consent may be wholly sufficient to protect members of the general public whose statements have been recorded under noncustodial conditions, such is not true when dealing with persons whose statements have been taken while under custodial arrest. In the latter situation, consent alone has been deemed insufficient. The legislature has authorized police to make sound recordings of statements made by arrested persons only under carefully circumscribed conditions.”
6 later decisions quote this exact passage“(1) Except as otherwise provided in this chapter, it shall be unlawful for ... the state of Washington, its agencies, and political subdivisions to intercept, or record any: . . .”
3 later decisions quote this exact passagee.g. State v. Cramer · State v. Brown
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.