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← 99 Haw. 312 - State v. Sprattling

State v. Sprattling’s Empirical Analysis

2002

Citation profile

41
cited by 41 later decisions
1
states following
January 2025
most recently cited

41 state decisions

How this case has been cited

Cited by 41 later decisions — most recently January 2025 · most notably State v. Wheeler (2009), State v. Cummings (2003)

41 state decisions

180200220102020decided

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 Neder v. United States · Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc. · Rogers v. Richmond · Hagner v. United States · Thompson v. City of Louisville

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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[a]ny error, defect, irregularity or variance which does not affect substantial rights shall be disregarded.”
    13 later decisions quote this exact passage · from the majority
  2. “and a defendant who challenges the omission for the first time on appeal must demonstrate substantial prejudice). This is because a defect in a complaint is not one of mere form, which is waivable, nor simply one of notice, which may be deemed harmless if a defendant was actually aware of the nature of the accusation against him or her, but, rather, is one of substantive subject matter jurisdiction,”
    3 later decisions quote this exact passage · from the concurrence
  3. “If there is such a reasonable possibility in a criminal case, then the error is not harmless beyond a reasonable doubt, and the judgment of conviction on which it may have been based must be set aside.”
    3 later decisions quote this exact passage · from the majority

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.