State v. Savage’s Empirical Analysis
1996
Citation profile
29 state decisions
How this case has been cited
Cited by 29 later decisions — most recently October 2018 · most notably Lucio v. State (2011), Rio Grande Valley Gas Co. v. City of Pharr (1997)
29 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 Burks v. United States · United States v. Wilson · Bigley v. State · State v. Moreno · State v. Evans
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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We have previously held that, “[wjhere the trial court, as in this case, enters a judgment notwithstanding the verdict, we treat it as the functional equivalent of an order granting a motion for new trial for insufficient evidence. A motion for new trial based on insufficiency of the evidence presents a legal rather than a factual question, and the trial court must apply the same legal test as that employed by the appellate court. The trial court must decide, after viewing the evidence in the light most favorable to the verdict, whether any rational trier of fact could have found the essential elements of the offense beyond a reasonable doubt. If the evidence meets the standard, it is an abuse of discretion for the trial court to grant the motion for new trial.””
1 later decision quote this exact passage · from the dissente.g. State v. Fowler“Nevertheless, trial courts do maintain the authority to order new trials for evidentiaiy sufficiency in criminal cases; a power which is the functional equivalent of granting a JNOV in a civil case. Therefore, when a jury returns a guilty verdict and the trial court grants the defendant’s motion for new trial based upon insufficiency of the evidence under Texas Rule of Appellate Procedure 30(b)(9), double jeopardy prevents the trial court from entering any other judgment than an acquittal.... Therefore, a trial court’s JNOV ruling after a jury determination of criminal guilt accomplishes exactly the same effect as granting the defendant a new trial for insufficient evidence — a functional acquittal.”
1 later decision quote this exact passage · from the dissent“the trial court does not have the authority to grant a different judgment-a judgment non obstante verdicto-than that rendered by the jury.”
1 later decision quote this exact passage
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.