Carroll v. State’s Empirical Analysis
1998
Citation profile
1 federal appellate · 22 state decisions
How this case has been cited
Cited by 23 later decisions — most recently May 2015
1 federal appellate · 22 state decisions
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 Johnson v. Zerbst · Soberon v. United States · Brewster v. Derwinski · Campbell v. Acuff-Rose Music, Inc. · Woolum v. Bank One, Lexington, N.A.
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“in a unitary trial where a defendant has pled guilty there exists no per se "punishment phase." In fact, unitization of the trial, where a defendant pleads guilty to a felony charge before a jury or judge, admits the existence of all facts necessary to establish guilt and, in such cases, the introduction of testimony by the State is to enable the jury or judge intelligently to exercise discretion in the assessment of punishment. Since appellant openly pled to the offenses in the indictment she is not eligible for a bifurcated trial ... but is instead subject to the rules of a unitary proceeding. Therefore, appellant's waiver extended to this proceeding.”
1 later decision quote this exact passage · from the majoritye.g. Carroll v. State“10. Pursuant to Article 1.14 of the Texas Code of Criminal Procedure, I waive all rights of form, substance or procedure given me by law. * * * . I waive my right not to incriminate myself, agree to testify if called as a witness and judicially confess under oath that each and every allegation contained in the indictment or information which is not waived by the State is true and I am guilty of the offense as charged.”
1 later decision quote this exact passage · from the majoritye.g. Carroll v. State“... [W]here a defendant pleads guilty either before a judge or jury the trial becomes "unitary." And as a result, there does not exist a separate punishment phase. Therefore, we hold that appellant's written waiver of her Fifth Amendment right not to self-incriminate applied to the entire criminal adjudication proceeding including the assessment of punishment.”
1 later decision quote this exact passage · from the majoritye.g. Carroll 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.