2016 Pa. Super. 211 - Commonwealth v. Kizak’s Empirical Analysis
2016
Citation profile
5
cited by 5 later decisions
1
states following
December 2023
most recently cited
5 state decisions
Relationships
Relies on Landgraf v. USI Film Products · Weaver v. Graham · Miller v. Florida · Commonwealth v. Young · Commonwealth v. Neiman
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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The amendment to the law in question was signed by the Governor of Pennsylvania on October 27, 2014. Over six weeks later, on December 10, 2014, Appellant committed the instant DUI offense. The amendment to [S]ection 3806(b) took effect on December 26, 2014. Furthermore, the legislature specified in the statute that the amendment of section 3806(b)"shall apply to persons sentenced on or after [December 26, 2014,] the effective date of this section." Act 2014-189 § 2 (emphasis added). Appellant was charged with the instant DUI offense on January 23, 2015. On May 20, 2015, Appellant entered her guilty plea. Thereafter, on July 14, 2015, the trial court, applying the amendment to section 3806(b), imposed Appellant's judgment of sentence. Here, the new law was not applied to events occurring before its enactment, that being October 27, 2014, because the instant offense was committed on December 10, 2014. Moreover, Appellant had fair notice of the change in the statute as her offense occurred more than six weeks after the amendment to the statute was signed into law. Accordingly, we are satisfied that there was no ex post facto violation in the instant matter.”
2 later decisions quote this exact passage“Also, Section 2 of Act 2014-189 provides that the amendment of [S]ection 3806(b) shall apply to persons sentenced on or after [December 26, 2014,] the effective date of this section.”
2 later decisions quote this exact passage“[U]nder the 2014 amendment, the ten-year 'look back' period for determining prior offenses became the date of sentencing and was no longer the date that the offense occurred.”
2 later decisions quote this exact passage
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.