Phifer v. State’s Empirical Analysis
1990
Citation profile
7
cited by 7 later decisions
1
states following
May 2010
most recently cited
7 state decisions
Relationships
Relies on Heredia v. State · Wheeler v. State · Rawlings v. State · 166 Tex. Crim. 301 - Edwards v. State · Childress v. State
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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Additionally, special enhancement provisions for a primary offense have long been held to bar enhancement under general statutes only for prior offenses that could be used within the special provisions. See Rawlings v. State, 602 S.W.2d 268 (Tex.Cr.App.1980); Heredia v. State, 468 S.W.2d 833 (Tex.Cr.App. 1971); Tomlin v. State, 170 Tex.Crim. 108 , 338 S.W.2d 735 (1960); Edwards v. State, 166 Tex.Crim. 301 , 313 S.W.2d 618 (1958). Applying that principle to this cause would preclude use of prior felony DWI convictions, but not other felony convictions, to enhance under Chapter 12.”
1 later decision quote this exact passagee.g. Bowley v. State
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.