State v. Matlack’s Empirical Analysis
1967
Citation profile
9 federal appellate · 6 district · 85 state decisions
How this case has been cited
Cited by 100 later decisions — most recently August 2008 · most notably Martinez v. State (1969), State v. Thompson (1971)
9 federal appellate · 6 district · 85 state decisions — followed in 11 states
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 United States v. Wade · Stovall v. Denno · Gilbert v. California · Ex parte Lange · Bozza v. United States
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 100 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Under the common law a judge could not increase or decrease a sentence once it had gone into operation. State v. Addy, 43 N.J.L. 113, 116 (Sup.Ct.1880). Our R.R. 3:7-13(a) modifies the common law by allowing a trial judge to reduce or change a sentence within time limitations, but does not empower him to increase sentences. Cf. State v. Laird, 25 N.J. 298, 307 , 135 A.2d 859 (1957). A rule which purported to allow a trial judge to increase a sentence previously imposed would raise serious problems under the constitutional right to be free from double jeopardy. See, United States v. Benz, 282 U.S. 304, 307-310 , 51 S.Ct. 113 , 75 L.Ed. 354, 356-358 (1931); Ex parte Lange, 18 Wall. 163, 173 , 21 L.Ed. 872, 878 (1874); United States v. Rosenstreich, 204 F.2d 321 (2d Cir. 1953); State v. Laird, supra, 25 N.J. at p. 312 , 135 A.2d 859 ; State v. Tyler, 88 N.J.Super. 396, 405-406 , 212 A.2d 573 (App.Div.1965), cert. den. 384 U.S. 992 , 86 S.Ct. 1898 , 16 L.Ed.2d 1008 (1966)."”
2 later decisions quote this exact passage · from the majority“is a prior identification of a party where identity is in issue, if made under circumstances precluding unfairness or unreliability.”
2 later decisions quote this exact passage · from the majority“The rule authorizes a trial judge subject to time limitations to “reduce or change” a sentence. We read this language to sanction reconsidered leniency and not severity. The word “reduce” obviously points to this interpretation; the word “change” seems directed only to differences in kind and not degree (e. g. fine in lieu of imprisonment): the omission of express authority to increase sentences in the context of the rule is highly significant. We conclude that this language does not authorize a trial judge to increase a sentence previously imposed by him. Under the common law a judge could not increase or decrease a sentence once it had gone into operation. State v. Addy, 43 N.J.L. 113, 116 (Sup.Ct.1880). Our R.R. 3:7-13(a) modifies the common law by allowing a trial judge to reduce or change a sentence within time limitations, but does not empower him to increase sentences. Cf. State v. Laird, 25 N.J. 298, 307 , 135 A.2d 859 (1957). A rule which purported to allow a trial judge to increase a sentence previously imposed would raise serious problems under the constitutional right to be free from double jeopardy. See United States v. Benz, 282 U.S. 304, 307-310 , 51 S.Ct. 113 , 75 L.Ed. 354, 356-358 (1931); Ex parte Lange [ 85 U.S. 163 ] 18 Wall. 163, 173 , 21 L.Ed. 872, 878 (1874); United States v. Rosenstreich, 204 F.2d 321 (2nd Cir. 1953); State v. Laird, supra, 25 N.J. at p. 312 ; State v. Tyler, 88 N.J.Super. 396, 405-406 , 212 A.2d 573 (App.Div.1965), cert. den. 384 U.S.”
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.