Penn v. State’s Empirical Analysis
1984
Citation profile
203 state decisions
How this case has been cited
Cited by 206 later decisions — most recently December 2023 · most notably State v. Larimore (2000), Pitts v. State (1999)
203 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 Troglin v. State · Anderson v. Buchanan · Smith v. State · Howard v. State · Gross 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 206 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) The function of the writ of coram nobis is to secure relief from a judgment rendered while there existed some fact which would have prevented its rendition if it had been known to the trial court and which, through no negligence or fault of the defendant, was not brought forward before rendition of judgment; (2) Coram nobis proceedings are attended by a strong presumption that the judgment of conviction is valid. The court is not required to accept at face value the allegations of the petition; (3) Due diligence is required in making application for relief, and, in the absence of a valid excuse for delay, the petition will be denied; and (4) The mere naked allegation that a constitutional right has been invaded will not suffice. The application should make a full disclosure of specific facts [relied] upon and not merely state conclusions as to the nature of such facts.”
2 later decisions quote this exact passage“By granting the right to petition the trial court, we do not in any way enlarge the other restrictions attendant to granting the writ. The trial court has the discretion to grant or deny it. The petitioner has a heavy burden to meet, especially in a case like this which must be approached with some skepticism for confessions by others are not uncommon. A written confession by another would not, alone, be grounds for relief. . . . We emphasize that we do not open the door to other petitions beyond those that would qualify under the facts in this case, especially the fact that it is presently between trial and appeal and can easily provide for an early hearing before the court that just heard the case. The petition was timely filed and if the confession is true, an injustice would obviously result if it were not granted.”
2 later decisions quote this exact passagee.g. Williams v. State · State v. Scott“We emphasize that we do not open the door to other petitions [for writ of coram nobis] beyond those that would qualify under the facts in this case, especially the fact that it is presently between trial and. appeal and can easily provide for an early hearing before the court that just heard the case. (Emphasis added.)”
2 later decisions quote this exact passagee.g. Larimore v. State · Brown 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.