Young v. State’s Empirical Analysis

Citation profile

82 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 83 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Whether entered with or without an agreed recommendation of punishment by the State, a valid plea of guilty or nolo contendere “waives” or forfeits the right to appeal a claim of error only when the judgment of guilt was rendered independent of, and is not supported by, the error.”

   10 later decisions quote this exact passage · from the majority
   e.g. Thomas, Heather · Reyes-Perez v. State

2. “provided, however, before the defendant who has been convicted upon either his plea of guilty or plea of nolo contendere before the court and the court, upon the election of the defendant, assesses punishment and the punishment does not exceed the punishment recommended by the prosecutor and agreed to by the defendant and his attorney may prosecute his appeal, he must have permission of the trial court, except on those matters which have been raised by written motion filed prior to trial.”

   4 later decisions quote this exact passage · from the majority
   e.g. Cooper v. State · Monreal v. State

3. “The Helms Rule, therefore imposes on a guilty plea the procedural consequence that was established in a line of federal cases from which it is descended — a knowing and voluntary plea of guilty waives claims of errors that preceded the plea. But it omits the rationale of the federal decisions, which is that a valid plea of guilty has this consequence because it is independent of such errors, and is sufficient to support the judgment of conviction. When the Helms Rule is applied to foreclose appellate review of a judgment that was not independent of an antecedent error, or a judgment that was based in part on inadmissible evidence to which proper objection was made, the consequence is not justified by the rationale of the rule. To be justified by its premises and consistent with its precedents, a rule of waiver would be imposed on pleas of guilty (or nolo contendere) only to the extent that the resulting judgment of conviction was independent of the error being raised on appeal.”

   2 later decisions quote this exact passage · from the majority
   e.g. Robuck v. State · Bradshaw v. State