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← 2016 WY 68 - Steven R. Barela v. State

Steven R. Barela v. State’s Empirical Analysis

2016

Citation profile

7
cited by 7 later decisions
1
states following
September 2024
most recently cited

7 state decisions

Relationships

Applies 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))

Relies on Hill v. United States · Olim v. Wakinekona · Block v. North Dakota Board of University and School Lands North Dakota Board of University and School Lands · Shields v. Beto · Gould v. State

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

  1. “Rule 85 authorizes challenges to illegal sentences only. An illegal sentence is defined as " 'one which exceeds statutory limits, imposes multiple terms of imprisonment for the same offense, or otherwise violates constitutions or the law'" Martinez v. State, 2002 WY 10, ¶ 9 , 39 P.3d 394, 396 (Wyo. 2002), quoting Duran v. State, 949 P.2d 885, 887 (Wyo. 1997), None of Mr. Pfeil's complaints pertain to the validity of the underlying sentence. Instead, he bootstraps his complaints over how his sentence is being administered into an argument that the [Board of Parole] and [Department of Corrections] have effectively altered his sentence to the extent it is now illegal. Rule 35 addresses only sentences which are illegal in fact, not sentences which inmates claim are being executed illegally by the 'State. See, eg., Gould v. State, 2006 WY 157, ¶ 25 , 151 P.3d 261, 268 (Wyo. 2006). It does not, therefore, provide an avenue to Mr. Pfeil for relief from the BOP's and DOC's actions.”
    1 later decision quote this exact passage
  2. “Sentencing decisions are normally within the discretion of the trial court. Bitz v. State, 2003 WY 140, ¶ 7 , 78 P.3d 257, 259 (Wyo. 2003). “Such discretion is limited, however, inasmuch as a court may not enter an illegal sentence. A sentence is illegal if it violates the constitution or other law.” In re CT, 2006 WY 101, ¶ 8 , 140 P.3d 643, 646 (Wyo. 2006) (internal case citation omitted). Whether a sentence’ is illegal is a question of law, which we review de novo. Manes v. State, 2007 WY 6, ¶ 7 , 150 P.3d 179, 181 (Wyo. 2007). Endris v. State, 2010 WY 73, ¶ 13 , 233 P.3d 578, 581 (Wyo. 2010) (quoting Jackson v. State, 2009 WY 82, ¶ 6 , 209 P.3d 897, 898-99 (Wyo. 2009).)”
    1 later decision quote this exact passage
  3. “Appellant's claims pertain to how his sentence has been administered by the Department of Corrections and the Board of Parole rather than the legality of his underlying sentence, Accordingly, Rule 85 does not provide an avenue of relief for Appellant.”
    1 later decision 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.