State v. Bello’s Empirical Analysis
2009
Citation profile
56 state decisions
How this case has been cited
Cited by 56 later decisions — most recently January 2025 · most notably State v. Brown (2012), State v. Inkelaar (2011)
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 Apprendi v. New Jersey · Blakely v. Washington · Ring v. Arizona · Cunningham v. California · State v. Gunby
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.
“'sentence enhancement' [factor] is the functional equivalent of an element of a greater offense than the one covered by the jury's guilty verdict. Indeed, it fits squarely within the usual definition of an 'element' of the offense.”
3 later decisions quote this exact passage · from the majoritye.g. State v. Brown · State v. Sanders““(a) (1) Except as provided in subsection (b) or (d), a defendant who is 18 years of age or older and is convicted of the following crimes committed on or after July 1, 2006, shall be sentenced to a term of imprisonment for life with a mandatory minimum term of imprisonment of not less than 25 years unless tire court determines that the defendant should be sentenced as determined in paragraph (2): (C) aggravated indecent liberties with a child, as defined in subsection (a)(3) of K.S.A. 21-3504, and amendments thereto.””
2 later decisions quote this exact passage · from the majority““(d) As identified in K.S.A. . . . 21-3502, . . . and amendments thereto, if the offender is 18 years of age or older and the victim is under 14 years of age, such violations are off-grid crimes for the purposes of sentencing. Except as provided in K.S.A. 21-4642, and amendments thereto, the sentence shall be imprisonment for life pursuant to K.S.A. 21-4643, and amendments thereto.” (Emphasis added.)”
2 later decisions quote this exact passage · from the majority
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.