Trimble v. State’s Empirical Analysis

Citation profile

3 state decisions

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

1. “'In Chapman v. California , 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967), the United States Supreme Court held that before a court's error in violating certain constitutional rights can be held harmless, the appellate court must be able to declare that the error was harmless beyond a reasonable doubt.'”

   2 later decisions quote this exact passage · from the majority
   e.g. Young v. State · 261 So. 3d 397 - Russell v. State

2. “"Although Rule 31(a), Ala. R. App. P., prohibits a party represented by counsel from filing a pro se brief, there is no specific rule addressing such a matter in the trial courts. However, disregarding a defendant's pro se pleading or motion is not generally subject to criticism when the defendant is represented by counsel. See Pardue v. State , 571 So.2d 320 , 329-30 (Ala. Crim. App. 1989), reversed on other grounds, 571 So.2d 333 (Ala. 1990). Although no Alabama appellate court decisions specifically address the particular issue raised in this case, courts in other jurisdictions have held that a defendant is not entitled to file pro se pleadings or motions when represented by counsel. See Hutchinson v. Florida , 677 F.3d 1097 , 1107 (11th Cir. 2012) ; Martin v. State , 797 P.2d 1209 , 1217 (Alaska Ct. App.1990) ('The trial court therefore has the authority to require a defendant who is represented by counsel to act through counsel.'). See also cases cited in Salser v. State , 582 So.2d 12 , 14 (Fla. Dist. Ct. App. 1991). The only exception to this rule applies to pro se motions requesting discharge of counsel. See Finfrock v. State , 84 So.3d 431 , 433-34 (Fla. Dist. Ct. App. 2012)."”

   1 later decision quote this exact passage · from the majority
   e.g. 265 So. 3d 387 - Gaston v. State

3. “"No judgment may be reversed or set aside ... on the ground of misdirection of the jury, the giving or refusal of special charges or the improper admission or rejection of evidence, nor for error as to any matter of pleading or procedure, unless in the opinion of the court to which the appeal is taken or application is made, after examination of the entire cause, it should appear that the error complained of has probably injuriously affected substantial rights of the parties."”

   1 later decision quote this exact passage
   e.g. 261 So. 3d 397 - Russell v. State