State v. Gefroh’s Empirical Analysis
1990
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently August 2021
14 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 Morrissey v. Brewer · Gagnon v. Scarpelli · Lorillard v. Pons · Dayton Board of Education v. Brinkman · Ralston v. Robinson
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘Section 12.1-32-07(4) ... was obviously intended to be the paramount legislation not only in defining criminal offenses but also in the area of sentencing and probation. Thus, even if there is a conflict between the two sections, and we do not concede there is, Section 12.1-32-07(4) controls. Therefore, in accordance with [State v.] Miller, [ 418 N.W.2d 614 (N.D.1988) ] the trial court, on December 29, 1988, was authorized under Section 12.1-32-07(4) to resentence Vavrosky to any sentence available at the time of the initial sentence, with credit given him for all time spent in custody as a result of the sentence for the crime of forgery.’ ””
1 later decision quote this exact passage · from the dissente.g. State v. Lindgren“Acceptance of Gefroh’s arguments would either encourage probationers to delay trial on independent prosecutions for substantive crimes constituting probation violations or deprive probation officers of the opportunity to “wait to assess the cumulative effect of several violations before initiating a revocation proceeding” by forcing probation officers to make revocation proceedings “an automatic reaction to technical or minor violations simply to preserve the government’s position[.]””
1 later decision quote this exact passagee.g. State v. Ballensky““The court, after a full investigation and a personal hearing, may revoke the suspension of the sentence of a person convicted of a felony and placed on probation and may terminate the probation and cause said person to suffer the penalty of the sentence previously imposed upon him, if the court shall determine at such hearing that the probationer has violated any of the rules and regulations prescribed for the conduct of probationers”
1 later decision quote this exact passage · from the dissente.g. State v. Lindgren
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.