Matthews v. State’s Empirical Analysis

Citation profile

1 federal appellate · 12 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Emerging from [a] survey of a quarter of a century of Maryland caselaw is the overarching principle that the values of finality and closure still abide, Rule 4-345(a) has been consistently interpreted to be a narrow window that permits a trial judge to correct at any time a sentence that is obviously and facially illegal in the sense that it is a sentence that the court had never been statutorily authorized to impose. It is not, on the other hand, some unlimited ‘Reopen, Sesame,’ licensing the court to revisit and to relitigate issues that have long since become faits accompli.””

   2 later decisions quote this exact passage
   e.g. 230 Md. App. 157 - Ray v. State · Carlini v. State

2. “the enigma that an illegal sentence is not always an illegal sentence.”

   2 later decisions quote this exact passage
   e.g. 239 Md. App. 297 - McKinney v. State · Carlini v. State

3. “The semantic problem arising out of those very different contexts is that the phrase “illegal sentence” has variable connotations and shifting meanings. Of all the illegal sentences that might deserve immediate appellate vacating in the broad context of direct review, only a small fraction are even cognizable in the austerely limited context of Rule Jp3Ip5(a) review. For the very reason that its meaning may shift, the phrase “illegal sentence” should never be lifted out of that first context and casually inserted into the second. The words may be the same, but they no longer mean the same thing. We cannot agree with Gertrude Stein that an illegal sentence is an illegal sentence is an illegal sentence, because sometimes it is not.”

   1 later decision quote this exact passage
   e.g. Carlini v. State