243 N.C. App. 425 - State v. Harwood’s Empirical Analysis

Citation profile

6 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[E]ven assuming the 2009 trial court made a mistake, we hold that this mistake would be a substantive error, rather than a clerical one. Changing this provision would retroactively extend defendant's period of probation by more than one year and would grant the trial court subject matter jurisdiction to activate five consecutive sentences of 6 to 8 months' imprisonment. Because this provision is substantive, we lack authority to change it[.]”

   1 later decision quote this exact passage
   e.g. 266 N.C. App. 393 - State v. Tincher

2. “[I]n order for a trial court to revoke a defendant's probation after the expiration of the period of probation, the State must have filed a written violation report before the expiration of the period of probation.”

   1 later decision quote this exact passage
   e.g. State v. Duff

3. “[w]e have repeatedly rejected attempts to change the substantive provisions of judgments under the guise of clerical error.”

   1 later decision quote this exact passage
   e.g. 266 N.C. App. 393 - State v. Tincher