433 Pa. Super. 111 - Commonwealth v. Quinlan’s Empirical Analysis
1994
Citation profile
2 federal appellate · 75 state decisions
How this case has been cited
Cited by 78 later decisions — most recently December 2025 · most notably Commonwealth v. Foster (2011), 434 Pa. Super. 309 - Commonwealth v. Anderson (1994)
2 federal appellate · 75 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 Benton v. Maryland · United States v. DiFrancesco · Ex parte Lange · Dennis v. California · Commonwealth v. Klinghoffer
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 78 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The power to modify a sentence in order to amend records, to correct mistakes of court officers or counsel’s inad-vertencies, or to supply defects or omissions in the record is inherent in our court system. Commonwealth v. Fiore, 341 Pa.Super. 305 , 491 A.2d 276 (1985). A sentencing court can, sua sponte, correct an illegal, sentence originally imposed, even after the defendant has begun serving the original sentence. Commonwealth v. Jones, 520 Pa. 385 , 554 A.2d 50 (1989). Where an initial punishment was procured by fraud, the trial court may decrease or increase the initial sentence. Id. Commonwealth v. Meyer, 169 Pa.Super. 40 , 82 A.2d 298 (1951). This inherent power of the court to correct obvious and patent mistakes is not eliminated by the expiration of the thirty-day appeal period. Commonwealth v. Cole, 437 Pa. 288 , 263 A.2d 339 (1970). In Cole , the Pennsylvania Supreme Court explained that an order granting both a new trial and an arrest of judgment was clearly contradictory; thus, the original order was patently erroneous and could be corrected even after the thirty days had passed. Id.”
2 later decisions quote this exact passage“Except as otherwise provided or prescribed by law, a court upon notice to the parties may modify or rescind any order within 30 days after its entry, notwithstanding the prior termination of any term of court, if no appeal from such order has been taken or allowed.”
2 later decisions quote this exact passage“Trial courts have the power to alter or modify a criminal sentence within thirty days after entry, if no appeal is taken.”
2 later decisions 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.