460 So. 2d 204 - Watts v. State’s Empirical Analysis
1983
Citation profile
13 state decisions
How this case has been cited
Cited by 13 later decisions — most recently August 2006
13 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 Crain v. United States · William Garland v. State of Washington · Rogers v. Peck · 51 Ala. App. 148 - Headley v. State · 41 Ala. App. 507 - Boyd v. State
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"`Due process of law . . . does not require the State to adopt any particular form of procedure, so long as it appears that the accused has had sufficient notice of the accusation and an adequate opportunity to defend himself in the prosecution. Rogers v. [Peck] , 199 U.S. 425 , 435 [ 26 S.Ct. 87 , 89 , 50 L.Ed. at 775 ].' "Alabama authority is in accord with the view that the common law formalities attendant on arraignment and plea are no longer required. See Headley v. State , 51 Ala. App. 148 , 283 So.2d 458 (1973); Boyd v. State , 41 Ala. App. 507 , 138 So.2d 60 (1962). "Overruling Crain v. United States , 162 U.S. 265 [625], 16 S.Ct. 952 , 40 L.Ed 1097 (1896), and quoting from the dissenting opinion in that case the Garland Court further stated: "`A waiver ought to be conclusively implied where the parties had proceeded as if defendant had been duly arraigned, and a formal plea of not guilty had been interposed, and where there was no objection made on account of its absence until, as in this case, the record was brought to this court for review. It would be inconsistent with the due administration of justice to permit a defendant under such circumstances to lie by, saying nothing as to such an objection, and then for the first time urge it in this court.' " Garland v. Washington , 232 U.S. at 646 , 34 S.Ct. at 457 , 58 L.Ed. at 775."”
2 later decisions quote this exact passage““It is not indispensable to the regularity of the conviction, that the accused should be formally arraigned. If he is advised of the offense with which he is charged, and is prepared, without hearing the indictment read, to answer it, he may plead. Here, it seems, that the prisoners were in Court, and when the solicitor announced the State ready to proceed with the case, their counsel answered, that they were also ready for trial. This amounts to a recognition, that they were the persons charged in the indictment in the case called, and were prepared to defend themselves against it. This was equivalent to, and in law, a sufficient substitute for an arraignment in due form””
1 later decision quote this exact passage“Alabama authority is in accord with the view that the common law formalities attendant on arraignment and plea are no longer required. See Headley v. State , 51 Ala. App. 148 , 283 So.2d 458 (1973); Boyd v. State , 41 Ala. App. 507 , 138 So.2d 60 (1962).”
1 later decision 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.