83 Wis. 2d 790 - Huggett v. State’s Empirical Analysis
1978
Citation profile
2 federal appellate · 80 state decisions
How this case has been cited
Cited by 86 later decisions (2 by the Supreme Court) — most recently June 2025 · most notably Bearden v. Georgia (1983), Coles v. State (1981)
2 federal appellate · 80 state decisions — followed in 11 states
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 Gagnon v. Scarpelli · Williams v. Illinois · 3 Cal. 3d 100 - In Re Antazo · 74 Wis. 2d 647 - State v. Tarrell · State v. Harris
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 86 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Restitution can aid an offender’s rehabilitation by strengthening the individual’s sense of responsibility. The probationer may learn to consider more carefully the consequences of his or her actions. One who successfully makes restitution should have a positive sense of having earned a fresh start and will have tangible evidence of his or her capacity to alter old behavior patterns and lead a law-abiding life. Conditioning probation on making restitution also protects the community’s interest in having the victims of crime made whole. However, conditioning probation on the satisfaction of requirements which are beyond the probationer’s control undermines the probationer’s sense of responsibility. Huggett v. State, 83 Wis.2d 790, 798 , 266 N.W.2d 403, 407 (1978).”
15 later decisions quote this exact passage“If the probationer lacks the capacity to pay and has demonstrated a good faith effort during probation, failure to make restitution cannot be "cause" for extending probation. As we have noted previously, the criminal justice system should not be employed to supplement a civil suit or as a threat to coerce the payment of a civil liability or to perform the functions of a collection agency.”
3 later decisions quote this exact passage““Failure to make restitution within the original probation period might constitute cause for extending probation and continuing restitution if there is a basis for believing that additional restitution would effectuate the objectives of probation . . . .” Id. at 803 (Emphasis added.)”
2 later decisions 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.