Beckworth v. State’s Empirical Analysis

Citation profile

16 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “"The United States Supreme Court had declared that a defendant convicted of capital murder must be allowed to present at the sentencing hearing a broad range of proposed mitigating evidence. The Court held: "`[W]e conclude that the Eighth and Fourteenth Amendments require that the sentencer, in all but the rarest kind of capital case, not be precluded from considering, as a mitigating factor, any aspect of a defendant's character or record and any of the circumstances of the offense that the defendant proffers as a basis for a sentence less than death.' " Lockett v. Ohio, 438 U.S. 586, 604 , 98 S.Ct. 2954 , 57 L.Ed.2d 973 (1978)(footnotes omitted). "By statute, Alabama law allows a broad spectrum of evidence to be offered as mitigation: "`In addition to the mitigating circumstances specified in Section 13A-5-51, mitigating circumstances shall include any aspect of a defendant's character or record and any of the circumstances of the offense that the defendant offers as a basis for a sentence of life imprisonment without parole instead of death, and any other relevant mitigating circumstance which the defendant offers as a basis for a sentence of life imprisonment without parole instead of death.' "§ 13A-5-52, Ala.Code 1975. "Our Supreme Court has previously stated: "`To determine the appropriate sentence, the sentencer must engage in a "broad inquiry into all relevant mitigating evidence to allow an individualized determination." Buchanan v. Angelone, 522 U.S. 269, 276 (1998)”

   3 later decisions quote this exact passage
   e.g. Beckworth v. State · Woods v. State

2. ““Plain error has been defined as a defect in the proceedings, whether or not the defect was brought to the attention of the trial court. Rule 45A, Ala. R.App. P., provides: “ ‘In all cases in which the death penalty has been imposed, the Court of Criminal Appeals shall notice any plain error or defect in the proceedings under review, whether or not brought to the attention of the trial court, and take appropriate appellate action by reason thereof, whenever such error has or probably has adversely affected the substantial right of the appellant.’ ” “ ‘The standard of review in reviewing a claim under the plain-error doctrine is stricter than the standard used in reviewing an issue that was properly raised in the trial court or on appeal. As the United States Supreme Court stated in United States v. Young, 470 U.S. 1 , 105 S.Ct. 1038 , 84 L.Ed.2d 1 (1985), the plain-error doctrine applies only if the error is “particularly egregious” and if it “seriously affect[s] the fairness, integrity or public reputation of judicial proceedings.” See Ex parte Price, 725 So.2d 1063 (Ala.1998), cert. denied, 526 U.S. 1133 , 119 S.Ct. 1809 , 143 L.Ed.2d 1012 (1999); Burgess v. State, 723 So.2d 742 (Ala.Cr.App.1997), aff'd, 723 So.2d 770 (Ala.1998), cert. denied, 526 U.S. 1052 , 119 S.Ct. 1360 , 143 L.Ed.2d 521 (1999); Johnson v. State, 620 So.2d 679, 701 (Ala.Cr.App.1992), rev’d on other grounds, 620 So.2d 709 (Ala.1993), on remand, 620 So.2d 714 (Ala.Cr.App.), cert. denied, 510 U.S. 905 , 11”

   1 later decision quote this exact passage
   e.g. 106 So. 3d 423 - Brandon Washington v. State of Alabama.

3. ““This Court recently summarized the legal principles relevant to our review of claims of error in a presentence report: “ ‘Section 13A-5-47, Ala.Code 1975, specifically states that before a circuit court may sentence a defendant convicted of a capital offense the circuit court must direct that a presentence report be prepared on the defendant. Rule 26.3(b), Ala. R.Crim. P., addresses the contents of the presentence report and states that the report may contain: “ ‘ “(1) A statement of the offense and the circumstances surrounding it; “‘“(2) A statement of the defendant’s prior criminal and juvenile report, if any; “ ‘ “(3) A statement of the defendant’s educational background; “ ‘ “(4) A statement of the defendant’s employment background, financial condition, and military record, if any; “ ‘ “(5) A statement of the defendant’s social history, including family relationships, marital status, interests, and activities, residence history and religious affiliations; ‘““(6) A statement of the defendant’s medical and psychological history, if available; ““‘(7) Victim Impact Statements; and “‘“(8) Any other information required by the Court.” “ ‘Here, the circuit court’s sentencing order clearly states that each party was given a copy of the presentence report, yet [appellant] never challenged any inaccuracies in the report. Section 13A-5-47(d), Ala.Code 1975, specifically provides that the circuit court must make “written findings of fact summarizing the crime and the defendant’s pa”

   1 later decision quote this exact passage · from the concurrence
   e.g. 65 So. 3d 452 - Yancey v. State