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← 61 Haw. 385 - State v. Sylva

State v. Sylva’s Empirical Analysis

1980

Citation profile

51
cited by 51 later decisions
2
states following
March 2023
most recently cited

4 district · 47 state decisions

How this case has been cited

Cited by 51 later decisions — most recently March 2023 · most notably State v. Sweet (1985), Franks v. City and County of Honolulu (1993)

4 district · 47 state decisions

23019801990200020102020decided

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 Lex Tex Ltd. v. Universal Textured Yarns, Inc. · Pacific Insurance Co., Ltd. v. Oregon Auto. Ins. Co. · State v. Ogata · In Re the Tax Appeal of Grayco Land Escrow, Ltd. · Huntsville Independent School District v. McAdams

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

  1. “If, as argued by the State, we were to follow the language of [HRS § 853-4(7)] literally, it would mean that every defendant with a juvenile record for offenses which would have been felonies if committed by an adult would be automatically disqualified from the benefits of DAG plea; it would simply make no difference if the defendant happens to have a juvenile record of a single offense incurred at age twelve, and he is before the court with an unblemished adult record as a "one-time, accidental or situational offender." We do not believe that the legislature intended such palpably absurd consequences.”
    1 later decision quote this exact passage · from the majority
  2. “(6) The defendant has been convicted of any offense defined as a felony by the [Hawai`i] Penal Code or has been convicted for any conduct which if perpetrated in this state would be punishable as a felony; (7) The defendant is found to be a law violator or delinquent child for the commission of an offense defined as a felony by the [Hawai`i] Penal Code or for any conduct which if perpetrated in this state would constitute a felony; (8) The defendant has a prior conviction for a felony committed in any state, federal, or foreign jurisdiction.”
    1 later decision quote this exact passage · from the majority
  3. “Subsection (7) when read independently of the other subsections appears to be clear and unambiguous,***. But statutory language must be read in the context of the entire statute and construed in a manner consistent with the purposes of the statute. ***Uncertainty as to the meaning of the statute may arise from the fact that giving a literal interpretation to the words would lead to such unreasonable, unjust, impracticable, or absurd consequences that they could not have been intended by the legislature.”
    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.