State v. Engelmann’s Empirical Analysis

Citation profile

15 state decisions

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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The withdrawal of a guilty plea before the imposition of sentence is within the sound discretion of the [circuit] court. When a defendant moves to withdraw a plea prior to sentencing, a court should exercise its discretion liberally in favor of withdraw. But, SDCL 23A-27-11 does not create an automatic right to withdraw a guilty plea. When deciding whether to allow a criminal defendant to withdraw his plea, the [circuit] court must look at the reasons why the plea is sought to be withdrawn and if the request to withdraw is obviously frivolous, the circuit court need not grant it.”

   2 later decisions quote this exact passage
   e.g. State v. Schmidt · State v. Irvine

2. “"The term `abuse of discretion' refers to a discretion exercised to an end or purpose not justified by, and clearly against, reason and evidence." "The withdrawal of a guilty plea before the imposition of sentence is within the sound discretion of the trial court." No defendant has an "absolute right to withdraw a guilty plea but the trial court's `discretion in the matter should be exercised liberally in favor of withdrawal, unless it appears that the State has detrimentally relied upon the plea and the prosecution of the defendant has been thereby prejudiced.'" "When deciding whether to allow a criminal defendant to withdraw [a guilty] plea, the trial court must look at the reasons why the plea is sought to be withdrawn and if the request to withdraw is obviously frivolous, the trial court need not grant it."”

   1 later decision quote this exact passage
   e.g. State v. Irvine

3. “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.”

   1 later decision quote this exact passage
   e.g. State v. Irvine