409 So. 2d 554 - State v. Randolph’s Empirical Analysis
1982
Citation profile
42 state decisions
How this case has been cited
Cited by 42 later decisions — most recently November 2018 · most notably 975 So. 2d 646 - State v. Pearson (2007), State v. Stec (1999)
42 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 404 So. 2d 1202 - State v. White
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a] motion for a new trial must be filed and disposed of before sentence.”
6 later decisions quote this exact passage · from the majority““However, counsel for Harold Randolph has called our attention to an error in his defendant’s sentencing. The minutes do not reflect that the trial court ruled on the application for a new trial before the [multiple offender] hearing on January 30, 1983. La.C.Cr.P. art. 853 provides in this regard that ‘a motion for a new trial must be filed and disposed of before sentence.’ Counsel has alleged no specific prejudice arising out of the apparent failure of the trial court to rule on the motion. See: State v. White, 404 So.2d 1202 (La.1981). Nevertheless, it is preferred, and Art. 853 requires, that the trial judge rule on the merits of an application for a new trial before imposing sentence on defendant. Therefore, ... we vacate the sentence of Harold Randolph and remand his case to the trial court for consideiation of the new trial motion. In the event of an unfavorable ruling on the motion, and resentencing, we reserve to defendant his right to appeal his conviction and sentence once more to this Court.” (Emphasis supplied.)”
1 later decision quote this exact passage · from the majority“Most recently, when faced with the lack of a ruling on defense motions for new trial and post verdict judgment of acquittal, this Court has returned to Randolph and, without addressing the merits of ^defendant’s assignments of error, vacated the defendant’s sentence and remanded for rulings on the motions, reserving to the defendant his right to appeal his conviction and sentence in the event of unfavorable rulings.”
1 later decision 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.