Mitchell v. State’s Empirical Analysis
1996
Citation profile
96 state decisions
How this case has been cited
Cited by 96 later decisions — most recently April 2018 · most notably Prystash v. State (1999), Huizar v. State (2000)
96 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 Huddleston v. United States · Almanza v. State · United States v. Beechum · Arline v. State · Grunsfeld 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 96 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[E]vidence may be offered by the [S]tate and the defendant as to any matter the court deems relevant to sentencing, including but not limited to the prior criminal record of the defendant, his general reputation, his character, an opinion regarding his character, the circumstances of the offense for which he is being tried, and, notwithstanding Rules 404 and 405, Texas Rules of Criminal Evidence, any other evidence of an extraneous crime or bad act that is shown beyond a reasonable doubt by evidence to have been committed by the defendant or for which he could be held criminally responsible, regardless of whether he has previously been charged with or finally convicted of the crime or act.”
8 later decisions quote this exact passage“[RJelevant case law shows that the importance of a charge on reasonable doubt has increased, not decreased, with the passage of time. We also note the court of criminal appeals’ statement in Mitchell that the use of extraneous offenses during the punishment phase should be analogous to that of the guilt/innocence phase of trial regarding burden of proof. Given the importance of the reasonable doubt charge, we hold that the Geesa paragraphs defining reasonable doubt as to extraneous offenses must be included in the jury charge at the punishment phase when requested.”
3 later decisions quote this exact passage · from the dissente.g. Rodgers v. State · Matz v. State“If a defendant, during the guilt/innocence phase, asks for an instruction to the jury on the standard of proof required for admitting extraneous offenses, the defendant is entitled to that instruction.”
1 later decision quote this exact passage · from the dissente.g. Parmer 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.