Randolph doctrine (Nebraska) · Go Syfert
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Randolph doctrine in Nebraska

13 Nebraska opinions name it 2 courts 1975–2026 5 in the last five years

The cases below were cited by Nebraska courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
State v. Duncangreen
neb · 2015 · cited in 7 Nebraska opinions naming this issue, 2015–2026
2 sentences

2016Later cases deemed this “the ‘Randolph doctrine.’” See State v. Duncan, 291 Neb. 1003, 1007 , 870 N.W.2d 422 , 425 (2015).

2015Laws, L.B. 998, § 13. 5 Id., § 20. 6 Legislative Journal, 103d Leg., 2d Sess. 1490 (Apr. 9, 2014). - 1007 - Nebraska A dvance Sheets 291 Nebraska R eports STATE v. DUNCAN Cite as 291 Neb. 1003 [2,3] Generally, if the Legislature amends a criminal statute by mitigating the punishment after the commission of a pro- hibited act but before final judgment, the punishment is that provided by the amendatory act unless the Legislature specifi- cally provided otherwise.7 We sometimes refer to this rule as the “Randolph doctrine,” after its progenitor.8 If a defendant appeals his or her sentence, then t

57
State v. Randolphgreen
neb · 1971 · cited in 5 Nebraska opinions naming this issue, 1975–2024
2 sentences

2024See State v. Randolph, 186 Neb. 297 , 183 N.W.2d 225 (1971). [14-16] Under the Randolph doctrine, when the Legislature amends a criminal statute by mitigating the punishment after the commission of a prohibited act but before final judg- ment, the punishment is that provided by the amendatory act unless the Legislature specifically provided otherwise.

2024See State v. Randolph, 186 Neb. 297 , 183 N.W.2d 225 (1971). [14-16] Under the Randolph doctrine, when the Legislature amends a criminal statute by mitigating the punishment after the commission of a prohibited act but before final judg- ment, the punishment is that provided by the amendatory act unless the Legislature specifically provided otherwise.

35
State v. Harrisgreen
nebctapp · 1998 · cited in 1 Nebraska opinions naming this issue, 1999–1999
2 sentences

1999See State v. Harris, 7 Neb.

1999See State v. Harris, 7 Neb.

11
State v. Karelgreen
neb · 1979 · cited in 1 Nebraska opinions naming this issue, 1999–1999
2 sentences

1999See, e.g., State v. Karel, 204 Neb. 573 , 284 N.W.2d 12 (1979) (holding that defendant’s right to jury trial was not defeated by substantive statutory changes improperly made by Revisor of Statutes).

1999See, e.g., State v. Karel, 204 Neb. 573 , 284 N.W.2d 12 (1979) (holding that defendant’s right to jury trial was not defeated by substantive statutory changes improperly made by Revisor of Statutes).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Nebraska. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
State v. Chacon green
neb · 2017
2 sentences

2026State v. Chacon, 296 Neb. 203 , 894 N.W.2d 238 (2017).

2026State v. Chacon, 296 Neb. 203 , 894 N.W.2d 238 (2017).

42017–2026
State v. Guardiola green
nebctapp · 2024
2 sentences

2026State v. Guardiola, 32 Neb.

2026State v. Guardiola, 32 Neb.

12026–2026
State v. Artis green
neb · 2017
2 sentences

2017Accordingly, Artis’ sentence appears to comply with L.B. 1094 in this respect. (c) Postrelease Supervision The State also suggests that Artis’ sentence may constitute plain error pursuant to the Randolph doctrine, because the ver- sion of § 29-2204.02 as amended by L.B. 1094 requires that Artis receive no period of postrelease supervision.26 Although the district court did not order postrelease supervision, the State is concerned that under the statutory scheme in effect at the time of Artis’ sentencing, a period of 9 months’ postrelease supervision could be imputed to him. 24 Committee Statem

2017Accordingly, Artis’ sentence appears to comply with L.B. 1094 in this respect. (c) Postrelease Supervision The State also suggests that Artis’ sentence may constitute plain error pursuant to the Randolph doctrine, because the ver- sion of § 29-2204.02 as amended by L.B. 1094 requires that Artis receive no period of postrelease supervision.26 Although the district court did not order postrelease supervision, the State is concerned that under the statutory scheme in effect at the time of Artis’ sentencing, a period of 9 months’ postrelease supervision could be imputed to him. 24 Committee Statem

12017–2017
State v. Aguallo green
neb · 2016
1 sentence

2016In State v. Aguallo, 294 Neb. 177 , ___ N.W.2d ___ (2016), the Nebraska Supreme Court recently addressed whether the reduced penalties for Class IIIA felonies contained in L.B. 605 applied to a sexual assault committed before August 30, 2015.

12016–2016
State v. Crisp green
neb · 1976
2 sentences

1982Nor is this a case such as presented in State v. Crisp, 195 Neb. 833 , 241 N.W.2d 129 (1976), wherein we refused to apply the Randolph doctrine.

1982Nor is this a case such as presented in State v. Crisp, 195 Neb. 833 , 241 N.W.2d 129 (1976), wherein we refused to apply the Randolph doctrine.

11982–1982

Statutes the citing opinions construe

NE § Neb. Rev. Stat. § 28-105 (11) NE § Neb. Rev. Stat. § 28-416 (3) NE § Neb. Rev. Stat. § 29-2204 (3) NE § Neb. Rev. Stat. § 29-2204.02 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NE 13 (1975–2026) FL 4 (1990–2025) IN 3 (2004–2016) OR 3 (2010–2022) MN 3 (1991–2008) TX 3 (2002–2013) AZ 2 (2005–2021) MS 2 (1999–2002) WI 2 (2005–2011) KS 2 (2021–2021) PA 2 (2007–2016) VA 2 (2005–2005) IL 2 (2003–2003) MO 2 (2020–2023) NJ 2 (2006–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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