State v. Lamb’s Empirical Analysis
2005
Citation profile
20 state decisions
How this case has been cited
Cited by 20 later decisions — most recently January 2023
20 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 Alonzo Bailey v. State of Alabama · State v. White · State v. Talty · Pollock v. Williams · Strattman v. Studt
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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(A) If a fine is imposed as a sentence or a part of a sentence, the court or magistrate that imposed the fine may order that the offender be committed to the jail or *Page 5 workhouse until the fine is paid or secured to be paid, or the offender is otherwise legally discharged, if the court or magistrate determines at a hearing that the offender is able, at that time, to pay the fine but refuses to do so. The hearing required by this section shall be conducted at the time of sentencing. {¶ 15} "(B) At the hearing, the offender has the right to be represented by counsel and to testify and present evidence as to the offender's ability to pay the fine. If a court or magistrate determines after considering the evidence presented by an offender, that the offender is able to pay a fine, the determination shall be supported by findings of fact set forth in a judgment entry that indicate the offender's income, assets, and debts, as presented by the offender, and the offender's ability to pay. {¶ 16} "* * * {¶ 17} "(D) No person shall be ordered to be committed to a jail or workhouse or otherwise be held in custody in satisfaction of a fine imposed as the whole or a part of a sentence except as provided in this section. Any person imprisoned pursuant to this section shall receive credit upon the fine at the rate of fifty dollars per day or fraction of a day. If the unpaid fine is less than fifty dollars, the person shall be imprisoned one day.”
1 later decision quote this exact passage“Id. at ¶ 12. Thus, we held that a defendant whose court costs had been converted to community service work cannot be jailed for failure to complete such service, as that would constitute imprisoning one for failure to work to satisfy a civil obligation. Id. With regard to contempt proceedings concerning the nonpayment of court costs, we stated: {¶ 20}”
1 later decision quote this exact passage“we nevertheless conclude that he cannot be jailed for failure to work off a civil debt such as court costs. To jail a defendant for failure to pay a civil obligation unquestionably would violate Section 15, Article I of the Ohio Constitution, which provides that '[n]o person shall be imprisoned for debt in any civil action.'”
1 later decision quote this exact passagee.g. Dibert v. Carpenter
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.