People v. Fowler’s Empirical Analysis

Citation profile

24 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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “has not transformed juvenile adjudications into criminal convictions; it simply has said that, under specified circumstances, a prior juvenile adjudication may be used to as evidence of past criminal conduct for the purpose of increasing an adult defendant's sentence. The Three Strikes law's use of juvenile adjudications affects only the length of the sentence imposed on an adult offender, not the finding of guilt in the adult court nor the adjudication process in the juvenile court.”

   2 later decisions quote this exact passage
   e.g. 152 Cal. App. 4th 1205 - People v. Nguyen · 146 Cal. App. 4th 1332 - People v. Nguyen

2. “A prior juvenile adjudication ... demonstrates beyond a reasonable doubt [citation] that a defendant has engaged in serious criminal behavior in the past [and] [b]y reoffending ... shows he has failed to draw the proper lesson from the previous judicial determination that he violated the law. This failure warrants harsher punishment in the adult proceeding.”

   2 later decisions quote this exact passage
   e.g. 152 Cal. App. 4th 1205 - People v. Nguyen · 146 Cal. App. 4th 1332 - People v. Nguyen

3. “consider a defendant's juvenile adjudications as evidence of past criminal conduct for the purpose of increasing an adult defendant's sentence.”

   2 later decisions quote this exact passage
   e.g. 152 Cal. App. 4th 1205 - People v. Nguyen · 146 Cal. App. 4th 1332 - People v. Nguyen