People v. Watts’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. “in addition to any other penalty prescribed by law.”

   5 later decisions quote this exact passage
   e.g. 4 Cal. 5th 1100 - People v. Ruiz · People v. Webb

2. “Section 11372.5's legislative evolution bolsters the conclusion that the Legislature's characterization of the crime-lab fee as a 'criminal laboratory analysis fee' reflects an intent to treat the charge as an administrative fee not subject to penalty assessments in circumstances that are not governed by the second paragraph of subdivision (a). When section 11372.5 was originally enacted in 1980, it required every person convicted of an enumerated offense to, 'as part of any fine imposed, pay an increment in the amount of fifty dollars ($50) for each separate offense.' (Stats. 1980, ch. 1222, § 1, p. 4140, italics added.) This portion of the statute was later amended to require every person convicted of a covered offense to 'pay a criminal laboratory analysis fee in the amount of fifty dollars ($50) for each separate offense.' (Stats. 1983, ch. 626, § 1, p. 2527.) The elimination of the reference to the fee's being part of the 'fine imposed' and its renaming from an 'increment' to a 'fee' strongly suggest that the Legislature did not intend the fee to be a 'fine, penalty, or forfeiture' because section 11372.5 calls it something else.”

   4 later decisions quote this exact passage
   e.g. 4 Cal. 5th 1100 - People v. Ruiz · People v. Webb

3. “the rationale of Martinez , Sierra , [and] the courts that have followed them, under which section 11372.5(a)'s references to the phrases 'total fine,' 'fine,' and 'any other penalty' somehow establish that the crime-lab fee constitutes a 'fine' or 'penalty' within the meaning of the statutes governing penalty assessments. As to the statute's reference to 'total fine,' we fail to perceive how the fact that the crime-lab fee increases the 'total fine' necessarily means the fee is itself a 'fine' subject to penalty assessments. Nothing about the statute's use of the phrase 'total fine' is inconsistent with the conclusion that the crime-lab fee simply gets added to the overall charge imposed on the defendant after penalty assessments are calculated. And as to the statute's references to the word 'fine' and the phrase 'any other penalty,' they appear only in section 11327.5(a)'s second paragraph, which applies only to offenses 'for which a fine is not authorized by other provisions of law.' " ( Watts , at p. 234, 206 Cal.Rptr.3d 202 .) The Watts court also adopted Vega's reasoning that "[t]he crime-lab fee ... is a fixed charge that is 'imposed to defray administrative costs,' not 'for retribution and deterrence.' ( Vega, supra , 130 Cal.App.4th at p. 195 [ 29 Cal.Rptr.3d 700 ] ; see also People v. Wallace (2004) 120 Cal.App.4th 867 , 876 [ 16 Cal.Rptr.3d 152 ] ['fee' is 'more nonpunitive term' than 'fine'].)”

   3 later decisions quote this exact passage
   e.g. People v. Webb · 219 Cal. Rptr. 3d 90 - People v. Moore