Snodgrass v. Robinson’s Empirical Analysis
512 F.3d 999 · 2008
Citation profile
4 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 8 later decisions — most recently December 2025
4 federal appellate · 1 district · 2 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
Applies 28 U.S.C. § 636
Relies on California Department of Corrections v. Morales · Connecticut Board of Pardons v. Dumschat · Garner v. Jones · Bagley v. Rogerson · State v. Snodgrass
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the focus of the ex post facto inquiry is not on whether a legislative change produces some ambiguous sort of “disadvantage,” nor ... on whether an amendment affects a prisoner’s “opportunity to take advantage of provisions for early release,” but on whether any such change alters the definition of criminal conduct or increases the penalty by which a crime is punishable. Simply put, not every change in the law raises ex post facto concerns. The changed law must create a “significant risk” of increasing the offender’s punishment. Here, Snodgrass’s claim does not hinge on the availability of parole, but on the availability of a commutation — the only means by which she might become eligi ble for parole. Whereas changes to parole procedures may, in some circumstances raise ex post facto concerns, changes to Iowa’s procedures for commutation applications do not. This is because most parole procedures are distinct from the highly personal, policy oriented, and legislatively unchecked authority of the Iowa governor to grant sentence commutations. The unpredictability of a wholly discretionary grant of commutation in Iowa precludes Snodgrass from demonstrating that the changes in Iowa’s law raise a “significant risk” that she will be denied a commutation she otherwise would have received. As such, she cannot demonstrate there is a significant risk her punishment will be longer than it would have been under former Iowa Code Section 902.2. Accordingly, she cannot make out an ex post f”
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.