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← 342 ARK 384 - Robinson v. State

Robinson v. State’s Empirical Analysis

2000

Citation profile

4
cited by 4 later decisions
1
states following
June 2003
most recently cited

4 state decisions

Relationships

Relies on Benton v. State · Hicks v. State · Weatherby v. Scenic Mountain Medical Center · Brown v. State · Webster 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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Similarly, in the case at hand the posttrial motions for a new trial were void and of no effect because they were filed before the judgments were entered. The notice of appeal in this case was filed forty-five days after the entry of the judgments. Since the posttrial motions did not extend the period of time in which to appeal due to their ineffectiveness, the appeal is untimely. The Robinsons contend that under one appellate rule for civil matters, and specifically under Ark. R. Civ. P. 59(b), new trial motions filed prematurely are deemed filed the day after judgment. However, that is not the case in criminal appeals as has been clearly set forth in Brown v. State, supra. The Robinsons also maintain that they were misled by the trial court, which held the hearing on the motions for new trial after the thirty-day period for filing a notice of appeal had passed. Placing the responsibility on the trial court is not enough to excuse the absence of subject-matter jurisdiction in this court. Daniels v. State, 338 Ark. 328 , 5 S.W.3d 1 (1999) (per curiam); Cook v. State, 327 Ark. 125 , 937 S.W.2d 641 (1997) (per curiam); Benton v. State, 325 Ark. 246 , 925 S.W.2d 401 (1996) (per curiam).”
    1 later decision quote this exact passage · from the majority
  2. “The issue before us is whether these posttrial motions were effective. Stated differendy, are posttrial motions following a criminal trial void and ineffective if filed before entry of the judgments? In Brown v. State, supra, a motion for new trial and motion for judgment notwithstanding the verdict were filed after the jury verdict but before entry of the judgment and commitment order. The appellant in that case had been found guilty of capital murder and the jury’s sentence was life in prison without the possibility of parole. The posttrial motions were premised on the fact that the jury only deliberated for ten minutes on the appellant’s guilt. We held that the issue raised in both posttrial motions was not preserved for our review. We said: As an initial matter, both the posttrial motions in this matter were ineffective because they were filed before the judgment was entered in this case. See Hicks v. State, 324 Ark. 450 , 921 S.W.2d 604 (1996) (per curiam); Webster v. State, 320 Ark. 393 , 896 S.W.2d 890 (1995) (per curiam). Because the motions are void, we treat them as if they had never been made.”
    1 later decision quote this exact passage

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.