Bingham v. State’s Empirical Analysis
1999
Citation profile
29 state decisions
How this case has been cited
Cited by 29 later decisions — most recently August 2015 · most notably Dewberry v. State (1999), Trevino v. State (1999)
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 Williamson v. United States · Coffin v. State · Cofield v. State · Davis v. State · Bingham 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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]hether a statement is self-inculpatory or not can only be determined by viewing it in context. Even statements that are on their face neutral may actually be against the declarant’s interest. "I hid the gun in Joe’s apartment” may not be a confession of a crime; but if it is likely to help the police find the murder weapon, then it is certainly self-inculpatory. "Sam and I went to Joe’s house” might be against the declarant’s interest if a reasonable person in the declar-ant's shoes would realize that being linked to Joe and Sam would implicate the declar-ant in Joe and Sam’s conspiracy. And other statements that give the police significant details about the crime may also, depending on the situation, be against the declarant’s interest. The question under Rule 804(b)(3) is always whether the statement was sufficiently against the declarant's penal interest "that a reasonable person in the declarant’s position would not have made the statement unless believing it to be true,” and this question can only be answered in light of all the surrounding circumstances.”
1 later decision quote this exact passage · from the dissente.g. Walter v. State“Nowhere within the text is there any mention of this exception being limited to cases in which the criminal defendant is the declarant of the statements, and there is good reason for this. The reason for this exception to the general exclusion of hearsay is that statements against interest are considered particularly trustworthy.... Thus, such statements are considered reliable, regardless of whether or not the criminal defendant is the declarant of the statement.”
1 later decision quote this exact passage · from the dissente.g. Dewberry v. State“Statement Against Interest. A statement which ... at the time of its making ... so far tended to subject the declar-ant to ... criminal liability ... that a reasonable person in declarant’s position would not have made the statement unless believing it to be true. In criminal cases, a statement tending to expose the declarant to criminal liability is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.”
1 later decision quote this exact passage · from the dissente.g. Frank 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.