611 So. 2d 495 - Crum v. State’s Empirical Analysis

Citation profile

6 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “"A Rule 32 petition attacking the appellant's most recent (triggering) convictions is not the proper forum in which to challenge the validity of the appellant's prior (underlying) convictions. The validity of a prior conviction should be challenged by filing a petition for post-conviction relief from that conviction. Lochli v. State , 565 So.2d 294 , 296 (Ala.Cr.App. 1990). Compare Ex parte Madden , 602 So.2d 1192 (Ala. 1991) (reaffirming the rule that when a defendant attacks the validity of a prior felony conviction used for purposes of enhancement, the proper forum is a separate Rule 32 petition addressed to that prior conviction)."”

   1 later decision quote this exact passage
   e.g. 623 So. 2d 400 - McHarris v. State

2. “Absent *Page 33 information from his client alerting him to a latent defect in the prior conviction that render[ed] that conviction unavailable to enhance sentence, counsel [was] not ineffective for failing to challenge the use of a facially-valid prior conviction for enhancement purposes. The appellant's Rule 32 petition did not allege that he informed his attorney at the guilty plea proceedings that the prior convictions upon which the State relied to enhance his sentence occurred during his minority and were not preceded by advice regarding his right to apply for youthful offender treatment”

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