Bird v. State’s Empirical Analysis

Citation profile

7 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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “A motion to correct an illegal sentence is not available for an attack on the validity of a conviction.”

   3 later decisions quote this exact passage
   e.g. Steven David Lunden v. The State of Wyoming · Gregory Michael Hawes v. State

2. “Bird II "). [¶6] In October 2000, Appellant filed a motion to correct illegal sentence claiming that his sentencing enhancements as a habit, ual criminal were illegal because his previous 'convictions were invalid. The district court denied the motion, finding that Appellant entered his pleas knowingly and voluntarily and that the pleas complied with the requirements for application of the habitual eriminal enhancement. subsequent appeal, concluding that the motion to correct illegal sentence was improper because Appellant's motion was "simply an attack on the soundness of the convictions underlying his habitual criminal enhancement and, accordingly, is not a proper subject for a Rule 35 motion.”

   1 later decision quote this exact passage
   e.g. Chester Loyde Bird v. State

3. “Therefore, issues concerning the validity of a conviction will not be addressed in the context of a Rule 35 motion.”

   1 later decision quote this exact passage
   e.g. Gregory Michael Hawes v. State