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← 265 GA 332 - State v. Evans

State v. Evans’s Empirical Analysis

1995

Citation profile

92
cited by 92 later decisions
2
states following
May 2023
most recently cited

92 state decisions

How this case has been cited

Cited by 92 later decisions — most recently May 2023 · most notably Smith v. State (2010), Maddox v. State (2005)

92 state decisions

3901995200020102020decided

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 Santobello v. New York · McCarthy v. United States · Valenzuela v. Newsome · Ford v. State · 204 Ga. App. 839 - Watt 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 92 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[I]t has been said that withdrawal is necessary to correct a manifest injustice if, for instance, a defendant is denied effective assistance of counsel, or the guilty plea was entered involuntarily or without an understanding of the nature of the charges.”
    4 later decisions quote this exact passage
  2. “Although before sentence is imposed the defendant has an absolute right to withdraw a guilty plea, see OCGA § 17-7-93, the harsher standard applicable to attempts to attack a guilty plea after sentence has been justified on several grounds. First, once sentence is imposed, the defendant is more likely to view the plea bargain as a tactical mistake and therefore wish to have it set aside. Second, at the time the sentence is imposed, other portions of the plea bargain agreement will often be performed by the prosecutor, such as the dismissal of additional charges or the return or destruction of physical evidence, all of which may be difficult to undo if the defendant later attacks his guilty plea. Finally, a higher post-sentence standard for withdrawal is required by the settled policy of giving finality to criminal sentences which result from a voluntary and properly counseled guilty plea.”
    2 later decisions quote this exact passage
  3. “to learn the factual basis from material contained in parts of the record other than the guilty plea hearing so long as the trial court makes clear on the plea hearing record that he is relying on those parts of the record and so long as those parts of the record are made a part of the record for appeal. [Cits.] In such an event, the record of the guilty plea hearing would show the trial court’s awareness of the factual basis of the plea.”
    2 later decisions 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.