State v. Lawrence’s Empirical Analysis
2007
Citation profile
107 state decisions
How this case has been cited
Cited by 107 later decisions — most recently April 2024 · most notably Crawford v. Commissioner of Correction (2009), State v. Casiano (2007)
107 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 Coastal Steel Corp. v. Wheelabrator-Frye, Inc. · United States v. Alaska · White v. Illinois · Roemer v. United States · White v. Illinois
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 107 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a challenge to the legality of a sentence focuses not on what transpired during the trial or on the underlying conviction. In order for the court to have jurisdiction over a motion to correct an illegal sentence after the sentence has been executed, the sentencing proceeding, and not the trial leading to the conviction , must be the subject of the attack.”
4 later decisions quote this exact passage · from the concurrence“and that courts are ''limited by the common-law rule that a trial court may not modify a sentence if the sentence was valid and its execution has begun.”
2 later decisions quote this exact passage · from the concurrencee.g. State v. Evans · State v. McCoy“It is well established that under the common law a trial court has the discretionary power to modify or vacate a criminal judgment before the sentence has been executed. ... This is so because the court loses jurisdiction over the case when the defendant is committed to the custody of the commissioner of correction and begins serving the sentence .... There are a limited number of circumstances in which the legislature has conferred on the trial courts continuing jurisdiction to act on their judgments after the commencement of sentence. ... See, e.g., General Statutes §§ 53a-29 through 53a-34 (permitting trial court to modify terms of probation after sentence is imposed); General Statutes § 52-270 (granting jurisdiction to trial court to hear petition for a new trial after execution of original sentence has commenced); General Statutes § 53a-39 (allowing trial court to modify sentences of less than three years provided hearing is held and good cause shown).... Without a legislative or constitutional grant of continuing jurisdiction, however, the trial court lacks jurisdiction to modify its judgment.”
1 later decision quote this exact passage · from the concurrence
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.