Donovan Spence v. Superintendent Commissioner’s Empirical Analysis
2000
Citation profile
6 district · 10 state decisions
How this case has been cited
Cited by 81 later decisions — most recently December 2023 · most notably State v. Stevens (2006), State v. Rivers (2007)
6 district · 10 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
Relies on Boykin v. Alabama · Johnson v. Zerbst · Coleman v. Thompson · Thomas v. Arn · Santobello v. New York
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 81 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[wjhere a sentencing court relies on the commission of an act ... as grounds for raising the defendant’s sentence for the original conviction, a petitioner may properly challenge the conclusion that he committed the ... act on the ground that he was actually innocent of it. Giving petitioner an opportunity to make this showing on collateral review, even if proeedurally defaulted on direct review, will prevent a quintessential miscarriage of justice: a person being punished for an act he did not commit.”
1 later decision quote this exact passage · from the majority“By challenging the determination of [the habeas applicant's] responsibility for the act predicating his enhanced sentence, [the habeas applicant] raises precisely the question that the actual innocence exception contemplates.”
1 later decision quote this exact passage · from the majoritye.g. In Re Carter“[T]he availability of actual innocence exception depends not on the `nature of the penalty' the state imposes, but on whether the constitutional error `undermined the accuracy of the guilt or sentencing determination.'”
1 later decision quote this exact passage · from the majoritye.g. In Re Carter
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.