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← 707 P2D 900 - State v. Andrews

State v. Andrews’s Empirical Analysis

1985

Citation profile

111
cited by 111 later decisions
4
states following
August 2023
most recently cited

111 state decisions

How this case has been cited

Cited by 111 later decisions — most recently August 2023 · most notably State v. Andrews (1986), 262 N.J. Super. 487 - State v. Smith (1993)

111 state decisions

53019851990200020102020decided

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 Bifulco v. United States · Garcia v. United States · State v. Chaney · Waters v. State · State v. Wortham

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

  1. “(e) Except as provided in (g) and (h) of this section, if the defendant has been convicted of two or more crimes, sentences of imprisonment shall run consecutively. If the defendant is imprisoned upon a previous judgment of conviction for a crime, the judgment shall provide that the imprisonment commences at the expiration of the term imposed by the previous judgment. (g) If the defendant has been convicted of two or more crimes before the judgment on either has been entered, any sentences of imprisonment may run concurrently if (1) the crimes violate similar societal interests; (2) the crimes are part of a single, continuous criminal episode; (3) there was not a substantial change in the objective of the criminal episode, including a change in the parties to the crime, the property or type of property right offended, or the persons offended; (4) the crimes were not committed while the defendant attempted to escape or avoid detection or apprehension after the commission of another crime; (5) the sentence is not for a violation of AS 11.41.100-11.41.470; or (6)the sentence is not for a violation of AS 11.41.500-11.41.530 that results in physical injury or serious physical injury as those terms are defined in AS 11.81.900.”
    6 later decisions quote this exact passage
  2. “If a statute establishing a penalty is susceptible of more than one meaning, it should be construed so as to provide the most lenient penalty.”
    2 later decisions quote this exact passage
  3. “[A] trial judge simultaneously sentencing a defendant for multiple crimes should impose a composite sentence ... reflecting the totality of the defendant’s conduct. A sentence for one count which might, viewed in isolation, appear excessive (or, by extension, too lenient) may not be clearly mistaken when viewed as a component in a composite sentence.... [A] person who is simultaneously sentenced for ten identical but separate criminal episodes should receive an incrementally greater sentence than one convicted of a single incident, but not ten times as great a sentence. In determining an appropriate incremental increase the trial court should consider the totality of the defendant’s conduct in comparison with the totality of the conduct of other sentenced offenders discussed in the reported cases.”
    1 later decision 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.