Hendrixson v. Lash’s Empirical Analysis
1972
Citation profile
26 state decisions
How this case has been cited
Cited by 26 later decisions — most recently November 2014 · most notably Hawkins v. Jenkins (1978), Dunn v. Jenkins (1978)
26 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 Federal Communications Commission v. WJR, Goodwill Station, Inc. · Lee v. United States · Dolan's Case · OVERLADE, WARDEN, ETC. v. Wells · Ex parte Vance
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The proposition that an unauthorized absence from confinement will extend the expiration date of a prisoner’s sentence, is well settled. Such an issue was presented to this court over 100 years ago in Ex Parte Clifford (1867), 29 Ind. 196 . That case involved a writ of habeas corpus in which the petitioner, who had escaped from prison and had been recaptured after the termination of his original sentence, complained that his confinement was illegal because it exceeded his original expiration date. It was determined that the appellant could not ‘avail himself of the fact that while he was illegally at large the date at which his imprisonment was to have terminated had passed.’ Id at 108. ‘[Sjince the liberty gained by the prisoner is wholly owing to his own wrong, there seems to be no reason why he should have any manner of advantage from it.’ Id. Other courts considering the question have consistently reached the same conclusion. Ex Parte Vance (1891), 90 Cal. 208 , 27 P. 209 ; Hollon v. Hopkins (1879), 21.Kan. 638; Dolan’s Case (1869), 101 Mass. 219 ; State ex rel. Siehl v. Jorgenson (1919), 176 Minn. 572 , 224 N.W. 156 ; Application of Edwards (1891), 43 N. J. Law 555, 39 Am. R. 610; Henderson v. James (1895), 52 Ohio St. 242 , 39 N.E. 805 . We believe the expression of the Massachusetts court in Dolan’s Case, supra, to be the most appropriate: ‘The petitioner seeks to be discharged on the ground that the term for which he was committed has expired by mere lapse of time; a”
1 later decision quote this exact passage““It is doubtful that the General Assembly meant to allow a prisoner to escape and have the period of his absence credited to his sentence”, and “The proposition that an unauthorized absence from confinement will extend the expiration date of a prisoner’s sentence is well settled”, citing Ex Parte Clifford, supra.”
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.