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← 522 SO2D 14 - Tillman v. State

Tillman v. State’s Empirical Analysis

1988

Citation profile

29
cited by 29 later decisions
3
states following
February 2015
most recently cited

29 state decisions

How this case has been cited

Cited by 29 later decisions — most recently February 2015 · most notably Tillman v. State (1991), 597 So. 2d 256 - Koenig v. State (1992)

29 state decisions

1601988199020002010decided

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 Santobello v. New York · 457 So. 2d 481 - State v. Neil · 522 So. 2d 18 - State v. Slappy · 521 So. 2d 1083 - Blackshear 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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Our decision in this case is controlled by the United States Supreme Court’s opinion in Santobello .... In that case, a New York prosecutor entered into a plea agreement with the defendant whereby the defendant would plead guilty to two misdemeanors, and the prosecutor would not make any sentence recommendation. In the interim between the plea agreement and the sentencing, the prosecutor who made the deal retired, and a new one was appointed to replace him. Unaware of the agreement, the new prosecutor recommended the maximum sentence, which the judge accepted. As in this case, the judge in Santobel-lo informed the attorneys that he was not at all influenced by the improper recommendation. The United States Supreme Court held that “when a plea rests to any significant degree on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled.” 404 U.S. at 262 , 92 S.Ct. at 499 . The Court noted that it was of no matter that the judge stated on the record that he would not be influenced by the inadvertent breach of the agreement. The mere breach of the agreement, regardless of the influence that breach would carry, or whether it was an intentional breach, was cause for remand.”
    2 later decisions quote this exact passage · from the majority
  2. “"In Santobello , the Court remanded the case to state court to determine the appropriate remedy, plea withdrawal or specific performance of the agreement. We are faced with a similar decision. The record discloses that the prosecution introduced evidence beyond what was agreed upon by the parties. This mere breach, no matter how slight, or whether the judge was influenced by it, is grounds for reversal. A defendant agrees to plead guilty based specifically on the agreement he or she has made with the state. Any breach of that agreement by the state renders the plea involuntary, as the plea is based on an agreement that was not fulfilled. " [e.s.]”
    2 later decisions quote this exact passage · from the majority
  3. “Part of the trial judge's role is to evaluate both the credibility of the person offering the explanation as well as the credibility of the asserted reasons. These must be weighed in light of the circumstances of the case and the total course of the voir dire, in question, as reflected in the record.”
    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.