Williams v. Duffy’s Empirical Analysis
1999
Citation profile
56 state decisions
How this case has been cited
Cited by 56 later decisions — most recently October 2020 · most notably Smith v. State (2010), Ellis v. State (2000)
56 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 Hill v. Lockhart · Zatsky v. United States · Strader v. Garrison · National Consultants, Inc. v. Burt · 210 N.J. Super. 427 - State v. Chung
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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“eligibility or ineligibility for parole is not a `consequence' of a plea of guilty, but a `matter of legislative grace' or a `consequence of the withholding of legislative grace.' (Cits.)”
3 later decisions quote this exact passage“"eligibility or ineligibility for parole is not a `consequence' of a plea of guilty, but a `matter of legislative grace' or a `consequence of the withholding of legislative grace.' (Cits.)" [Cit.] Thus, OCGA § 17-10-6.1(c)(3) would have only a collateral effect on Duffy's sentence for armed robbery, in no way lengthening the sentence itself, but conditioning satisfaction of that sentence upon Duffy's incarceration for the designated 15-year period. [Cits.] There is no constitutional requirement that a defendant be advised of such collateral consequences in order for his guilty plea to be valid. [Cits.] If a defendant's actual knowledge of such collateral consequences is not a prerequisite to his entry of a knowing and voluntary guilty plea, his lack of knowledge of those collateral consequences cannot affect the voluntariness of the plea. (Cit.) Accordingly, counsel's failure to advise the defendant of the collateral consequences of a guilty plea cannot rise to the level of constitutionally ineffective assistance. [Cit.] [21]”
1 later decision quote this exact passage“The majority equates “constitutionally ineffective assistance” with the deficiency prong. However, deficient performance is only “constitutionally ineffective” when it causes prejudice. In looking at the deficiency prong separately, I would hold that defense counsel’s obligation to his client in entering a guilty plea is not defined by a trial court’s duties in accepting a guilty plea. While the two concepts are interrelated, I am persuaded that the more logical approach is to recognize that a defendant’s sixth amendment claim of ineffective assistance of counsel is separate from a due process claim that a plea was not knowingly and voluntarily made.”
1 later decision quote this exact passage · from the dissente.g. Alexander v. State
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.