Colvin v. State’s Empirical Analysis

Citation profile

17 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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The illegality inheres in Petitioner's sentence because the trial court lacked the requisite authority to impose the enhanced sentence. An illegal sentence, for purposes of Rule 4-345(a), is one in which the illegality inheres in the sentence itself ; i.e. , there either has been no conviction warranting any sentence for the particular offense or the sentence is not a permitted one for the conviction upon which it was imposed and, for either reason, is intrinsically and substantively unlawful.”

   2 later decisions quote this exact passage
   e.g. 236 Md. App. 368 - Rainey v. State · Bailey v. State

2. “'[a] motion to correct an illegal sentence is not an alternative method of obtaining belated appellate review of the proceedings that led to the imposition of judgment and sentence in a criminal case.' " Colvin , 450 Md. at 725 , 150 A.3d 850 (quoting State v. Wilkins , 393 Md. 269 , 273, 900 A.2d 765 (2006) ). Determining whether an illegality "inheres in the sentence itself”

   1 later decision quote this exact passage
   e.g. 236 Md. App. 368 - Rainey v. State

3. “Under Maryland law, procedural challenges to a verdict ought be done by contemporaneous objection and, if not corrected, presented through the direct appeal process. Such claims do not come within the purview of Rule 4-345(a).”

   1 later decision quote this exact passage
   e.g. 234 Md. App. 564 - Grandison v. State