State v. Wahle’s Empirical Analysis
1994
Citation profile
11 state decisions
How this case has been cited
Cited by 11 later decisions — most recently April 2024
11 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 United States v. Peter A. Crusco and Phillip A. Cimmino. Appeal of Phillip Cimmino · State v. Grosh · State v. Lohnes · United States v. Dalman
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the withdrawal of a guilty plea, even prior to sentencing, is not subject to the whim or caprice of the defendant. Rather, it is a matter that lies solely within the discretion of the trial court. Although, before sentencing, that discretion is to be exercised liberally in favor of withdrawal, the trial court must still look at the reasons why withdrawal is sought. If ... there is sufficient objective proof on the record of the defendant's misunderstanding of the maximum sentence he faced, then the plea is considered to have been entered without full knowledge of the consequences and involuntarily. Under these circumstances, the trial court's discretion should favor withdrawal of the guilty plea. However... if the request to withdraw is frivolous, the trial court need not grant it.”
2 later decisions quote this exact passage · from the majority“Where the record shows that `circumstances as they existed at the time of the guilty plea, judged by objective standards, reasonably justified [a defendant's] mistaken impression,' a defendant must be held to have entered [the] plea without full knowledge of the consequences and involuntarily.”
2 later decisions quote this exact passage · from the majoritye.g. Lien v. Class · State v. Engelmann“A motion to withdraw a plea of guilty ... may be made only before sentence is imposed or imposition of sentence is suspended; but to correct manifest injustice a court after sentence may set aside a judgment of conviction and permit the defendant to withdraw his plea.”
2 later decisions quote this exact passage · from the majoritye.g. State v. Goodwin · State v. Olson
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.