Commonwealth v. Bebout’s Empirical Analysis

Citation profile

14 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “it must at least be plausible that one could survive to the minimum release date with some consequential likelihood that a non-trivial amount of time at liberty awaits.”

   2 later decisions quote this exact passage
   e.g. Commonwealth v. White · Commonwealth v. Lekka

2. “[Bebout's] opportunity for release [was] meaningful, especially in light of the gravity of his crime, because he has the potential to live for several decades outside of prison if paroled at his minimum. Thus, based on the record and arguments before us we conclude that [Bebout] has simply failed to meet his burden of demonstrating that the lower court sentenced him to a de facto LWOP sentence. There simply is no comparison between the opportunity to be paroled at 60 years of age and 100+ years of age. The difference is, quite literally, a lifetime. As such, we are not convinced that [Bebout's] sentence is the functional equivalent of LWOP.”

   1 later decision quote this exact passage
   e.g. Commonwealth v. White

3. “a trial court may not impose a term-of-years sentence on a juvenile convicted of homicide if that term-of-years sentence equates to a de facto [life-without-parole] sentence unless it finds, beyond a reasonable doubt, that the juvenile is incapable of rehabilitation.”

   1 later decision quote this exact passage
   e.g. Commonwealth v. Lekka