State v. Roderick’s Empirical Analysis

Citation profile

90 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 90 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[a] prior conviction is any conviction, other than another count in the current case, which was brought in the same information or complaint or which was joined for trial with other counts in the current case pursuant to K.S.A. 22-3203 . . . which occurred prior to sentencing in the current case.”

   3 later decisions quote this exact passage · from the majority
   e.g. 25 Kan. App. 2d 696 - State v. Bandy · State v. Patry

2. ““Legislative history answers the question of whether Roderick’s situation should be treated as a K.S.A. 1994 Supp. 21-4720(b) ‘multiple conviction case.’ K.S.A. 1993 Supp. 21-4720(b)(4) provided in part: ‘The total sentence assigned for a current conviction event cannot exceed twice the base sentence.’ The term ‘conviction event’ was defined at K.S.A. 1993 Supp. 21-4703(c) (the guidelines definition section) as ‘one or more felony convictions occurring on the same day and within a single court. These convictions may result from multiple counts within an information or from more than one information.’ “In 1994, the legislature deleted all references to conviction events from the guidelines (from 21-4703 in L. 1994, ch. 291, § 49; from 21-4720(b)(4) in L. 1994, ch. 291, § 59). The legislature provided that the limits on the total sentence would apply to ‘multiple convictions arising from multiple counts within an information, complaint or indictment.’ K.S.A. 1994 Supp. 21-4720(b)(4). The legislature changed a same day, single court requirement to a same information or complaint requirement to invoke tire double rule limit. The change was made for the purpose of ‘limiting the application of the “double rule” limit for consecutive sentence[s] to multiple [counts] in the same case rather than all counts for which the defendant was convicted at one time, regardless of whether from different cases.’ Kansas Report on Legislative Interim Studies, p. 116 (1994). “Roderick’s situation w”

   2 later decisions quote this exact passage · from the majority
   e.g. State v. McCurry · 24 Kan. App. 2d 882 - State v. Bolin

3. ““The fundamental rule of statutory construction is that the intent of the legislature governs when that intent can be ascertained from the statute. State v. Roderick, 259 Kan. 107, 110 , 911 P.2d 159 (1996). The general rule is that criminal statutes must be strictly construed in favor of the accused. Any reasonable doubt about the meaning is decided in favor of anyone subjected to the criminal statute. The rule of strict construction, however, is subordinate to the rule that judicial interpretation must be reasonable and sensible to effect legislative design and intent. [Citations omitted.]””

   2 later decisions quote this exact passage · from the majority
   e.g. 27 Kan. App. 2d 805 - State v. Petz · State v. Crank