207 N.J. Super. 126 - State v. Reyes’s Empirical Analysis
1986
Citation profile
74 state decisions
How this case has been cited
Cited by 77 later decisions — most recently March 2018 · most notably State v. Davis (1994), Commonwealth v. Durling (1990)
74 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 18 U.S.C. § 3006A (Criminal Justice Act)
Relies on Morrissey v. Brewer · Gagnon v. Scarpelli · Bearden v. Georgia · Blanton v. General Electric Credit Corp. · State v. Johnson
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 77 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Revocation of probation is not a stage in a criminal prosecution, but, rather, a part of the corrections process____ A violation-of-probation hearing is summary in nature. That was plainly expressed in the repealed N.J.S.A 2A:168-4 and is implicit in the current N.J.S.A. 2C:45-3a(4). In both Gagnon [v. Scarpelli ] (involving probation), and Morissey [v. Brewer] (involving parole), the [United States] Supreme Court stressed the informal and flexible nature of revocation hearings and the lack of need or justification for the range of protections available to defendants in criminal trials. New Jersey has not imposed stricter state constitutional standards on probation violation hearings than the United States Constitution demands. By what standard is a court to be “satisfied” that a violation occurred? Proof of violation beyond a reasonable doubt is not constitutionally required as it is in criminal trials____ ... We hold, therefore, that a court may not find a violation of probation unless defendant has been convicted of another offense or the court is satisfied by a preponderance of the evidence that defendant has inexcusably failed to comply with a substantial requirement imposed as a condition of probation. [Citations omitted.]”
3 later decisions quote this exact passage · from the majority“The defendant shall receive credit on the term of a custodial sentence for any time he has served in custody in jail or in a state hospital between his arrest and the imposition of sentence.”
2 later decisions quote this exact passage · from the majority“[t]he admission and consideration of reliable hearsay evidence in probation violation proceedings [to be] both fair and practical.”
2 later decisions quote this exact passage · from the majoritye.g. State v. Mosley · Matter of CA
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.