Ex Parte Chambers’s Empirical Analysis
1987
Citation profile
1 federal appellate · 56 state decisions
How this case has been cited
Cited by 57 later decisions — most recently December 2006 · most notably Lancaster v. State (1993), 547 So. 2d 68 - Ex Parte Brannon (1989)
1 federal appellate · 56 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 392 So. 2d 1274 - Watson v. State · 392 So. 2d 1280 - Sanders v. State · 414 So. 2d 998 - Dickerson v. State · 54 Ala. App. 707 - Palmer v. State · 421 So. 2d 1299 - Aplin 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 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The Habitual Felony Offender Act, with its punishment enhancement provisions, is a penal statute, and must be strictly construed, especially in regard to its applicability to felony offenses outside the Criminal Code. A careful reading of the pertinent provisions of Title 13A, Chapter 5, along with the commentary thereto, makes it quite obvious that the legislature did not intend the Habitual Felony Offender Act to apply to felony drug offenses. That legislative intent is made unequivocal by the inclusion of a recidivist statute in the Controlled Substances Act itself, the enhancement provisions of which are plainly applicable to the facts of the present case. [[Image here]] “... Because the sentences applicable to drug offenses and repeat drug offenses are provided within the Controlled Substances Act, we hold that defendants convicted thereunder must be sentenced according to its provisions, not the sentencing provisions of Title 13A.””
6 later decisions quote this exact passagee.g. Kennedy v. State · Ward v. State“". . . Because the sentences applicable to drug offenses and repeat drug offenses are provided within the Controlled Substances Act, we hold that defendants convicted thereunder must be sentenced according to its provisions , not the sentencing provisions of Title 13A." Chambers , 522 So.2d at 316 (emphasis in original).”
4 later decisions quote this exact passage“"When the legislature revised the Criminal Code in 1977, particularly Title 13A, Chapter 5, having to do with punishments and sentences, it was well aware that the penalties set out in that chapter would not necessarily be applicable to all criminal offenses defined outside Title 13A. This is made clear in § 13A-5-1 , [Ala. Code 1975,] which sets out the applicability of the provisions of Chapter 5: "`(a) Every person convicted of any offense defined in this title, or defined outside this title shall be sentenced by the court in accordance with this article, unless otherwise specifically provided by law. "`(b) Penal laws enacted after January 1, 1980 shall be classified for punishment purposes in accordance with this article.' "Particularly illuminating is the commentary to the above section, as it pertains to subsection (a): "`Subsection (a) makes it clear that sentences for all offenses, both within and outside the Criminal Code, must be imposed in accordance with the Criminal Code, "unless otherwise specifically provided by law." Since all offenses defined in this Criminal Code have been specifically classified, the provision is aimed primarily at offenses outside the Criminal Code, i.e. , sections of the Alabama Code of 1975 that are not repealed upon adoption of this Criminal Code. However, there will always be some exceptions where different, or special, sections may apply. For example, drug offenses are not covered in this Criminal code, but are governed by the Alabama”
3 later decisions 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.