Matthews v. State’s Empirical Analysis

Citation profile

10 state decisions

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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[W]hen establishing Strickland prejudice in the context of plea counsel's failure to request a mental competency evaluation, the applicant need only show a reasonable probability that he was incompetent at the time of the plea.”

   2 later decisions quote this exact passage
   e.g. Garren v. State · Ramirez v. State

2. “Due process prohibits the conviction of an incompetent defendant, and this right may not be waived by a guilty plea. Jeter v. State, [ 308 S.C. 230 , 417 S.E.2d 594, 595-596 ] (1992) (citations omitted). In a [post-conviction relief] action, the petitioner must prove by a preponderance of the evidence that he was incompetent when he entered his guilty plea. Id. at 232 [, 417 S.E.2d at 596 ]; Rule 71.1(e), SCRCP. In order to find that petitioner’s trial counsel was ineffective for refusing to request a ... hearing on petitioner’s competency to stand trial, petitioner must show that counsel was deficient and that the deficiency prejudiced the outcome of petitioner’s proceedings. In [Jeter, 417 S.E.2d at 596 ], this Court proclaimed that in proving Strickland prejudice within the context of counsel’s failure to fully investigate the petitioner’s mental capacity, “the [petitioner] need only show a ‘reasonable probability’ that he was ... incompetent at the time of the plea.””

   1 later decision quote this exact passage
   e.g. Ridgley v. State

3. “Due process prohibits the conviction of an incompetent defendant, and this right may not be waived by a guilty plea.”

   1 later decision quote this exact passage
   e.g. Garren v. State