State v. Chyle’s Empirical Analysis
1980
Citation profile
2 federal appellate · 12 state decisions
How this case has been cited
Cited by 15 later decisions — most recently November 2022
2 federal appellate · 12 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 In the Matter of Samuel Winship · Sandstrom v. Montana · County Court of Ulster Cty. v. Allen · United States v. United States Gypsum Co. · State v. Allen
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In light of the fact that the amended judgment in this case did not go to the essence of Chyle’s conviction, it would appear that he may have been the beneficiary of several extra days in which to decide whether or not to file an appeal. However, to strictly interpret Rule 4(b), N.D.R.App.P., and its counterpart, Rule 37(b), N.D.R.Crim.P., as applying to an original judgment, rather than a final judgment, could have the effect of working an injustice on a potential appellant where the subsequent amended judgment proved particularly onerous or came at a time beyond 10 days after the original judgment had been filed. These possibilities, linked with the fact that Chyle specifically stated that he was appealing ‘from the judgment of the above named Court entered on March 5, 1980, ... ’ lead us to deny the State’s motion to dismiss the appeal.” Chyle, supra, 297 N.W.2d at 411 .”
1 later decision quote this exact passagee.g. State v. Neigum“[i]f the instruction on `intent' ... had been given in a situation more closely akin to Sandstrom ... we might agree that a substantial right may have been affected and that ... Rule 52(b), N.D.R.Crim.P., would apply.”
1 later decision quote this exact passagee.g. State v. Trieb
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.