161 Ohio App. 3d 274 - State v. Lett’s Empirical Analysis
2005
Citation profile
49 state decisions
How this case has been cited
Cited by 49 later decisions — most recently October 2023 · most notably State v. Foster (2006), In re Ohio Criminal Sentencing Statutes Cases (2006)
49 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
Applies 18 U.S.C. § 3742
Relies on United States v. Booker · Apprendi v. New Jersey · Blakely v. Washington · Shepard v. United States · Pierce v. Underwood
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'Concurrent sentences, however, require a positive act by the trial court, and in the absence of a declaration thereof by the trial court, it is presumed such sentences will run consecutively.'”
6 later decisions quote this exact passage“the findings required under R.C. 2929.14 (E)(4) * * * for imposing consecutive sentences do not violate an offender's Sixth Amendment right to a trial by jury as construed in Blakely .”
2 later decisions quote this exact passage“(1) necessary to protect the public from future crime or to punish the offender; (2) not disproportionate to the seriousness of the offender's conduct and to the danger the offender poses to the public; and (3) the court finds one of the following: (a) the crimes were committed while awaiting trial or sentencing, under sanction, or under post-release control; (b) the harm caused by multiple offenses was so great or unusual that a single prison term would not adequately reflect the seriousness of his offense; or (c) the offender's criminal history demonstrates that consecutive sentences are necessary to protect the public from future crime.”
1 later decision quote this exact passage · from the dissent
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.