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← 257 Va. 87 - Commonwealth v. Sandy

Commonwealth v. Sandy’s Empirical Analysis

1999

Citation profile

18
cited by 18 later decisions
2
states following
December 2012
most recently cited

18 state decisions

Relationships

Relies on Mabry v. Johnson · Greene v. Massey · State v. Collins · 95 Wash. 2d 799 - State v. Wheeler · Shields 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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “A plea bargain standing alone is without constitutional significance; in itself it is a mere executory agreement which, until embodied in the judgment of a court, does not deprive an accused of liberty or any other constitutionally protected interest. It is the ensuing guilty plea that implicates the Constitution. Only after [the defendant] pleaded guilty was he convicted, and it is that conviction which gave rise to the deprivation of [the defendant’s] liberty at issue here. [Mabry, 467 U.S.] at 507-08, 104 S.Ct. [at 2546] (footnotes omitted).”
    1 later decision quote this exact passage · from the majority
  2. “Absent judicial approval or prejudice to a criminal defendant, a proposed plea agreement cannot be binding upon the Commonwealth because the defendant has suffered no harm, and the defendant is [likewise] free to reject the proposed agreement before it is submitted to a court in spite of any prejudice that the Commonwealth may have incurred.”
    1 later decision quote this exact passage · from the majority
  3. “We hold that a Commonwealth's Attorney may withdraw from a proposed plea agreement at any time before the actual entry of a guilty plea by a defendant or any other change of position by the defendant resulting in prejudice to him because of reliance upon the agreement.”
    1 later decision quote this exact passage · from the majority

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.