97 Ohio App. 3d 515 - State v. Chappell’s Empirical Analysis
1994
Citation profile
44 state decisions
How this case has been cited
Cited by 44 later decisions — most recently July 2025 · most notably 145 Ohio App. 3d 706 - State v. Geboy (2001), 114 Ohio App. 3d 306 - State v. Jones (1996)
44 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 State v. Jenks · 20 Ohio App. 3d 172 - State v. Martin · Ohio v. Roberts · Pointer v. Texas · State v. Dehass
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 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“for purposes of medical diagnosis and treatment”
4 later decisions quote this exact passage“We would not adopt a rigid rule as to what constitutes `diagnosis and treatment' or limit diagnosis and treatment to licensed physicians, as such a narrow holding would undercut the function of nurses, psychiatrists, therapists, and various individuals who treat victims of sexual abuse. We are equally not prepared to hold that a social worker, by merely being a social worker, is automatically included in the category of individuals who can render treatment or diagnose sex abuse victims. The inclusion of a social worker into this select group of care providers must depend on her function. Where a social worker's function does not include diagnosis or treatment (whether it be mental or physical treatment of a child sex abuse victim), any statement made to the social worker cannot be admissible under the exception to the hearsay rule in Evid. R. 803(4). * * *.”
2 later decisions quote this exact passage“Additionally, when deciding whether a statement is an excited utterance, the court should consider: (a) the lapse of time between the event and the declaration; (b) the mental and physical condition of the declarant; (c) the nature of the statement; and (d) the influence of intervening circumstances.”
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.