Higdon v. Cooper, 279 S.E.2d 451 (Ga. 1981). · Go Syfert
Higdon v. Cooper, 279 S.E.2d 451 (Ga. 1981). Cases Citing This Book View Copy Cite
42 citation events (9 in the last 25 years) across 4 distinct courts.
Strongest positive: Stanli Owens v. State (gactapp, 2014-03-28) · Strongest negative: Christian Evans Hughes v. State (gactapp, 2022-02-23)
Treatment trajectory · 1981 → 2026 · click a year to view as-of
1981 2003 2026
Top citers, strongest first. 7 distinct citers.
discussed Overruled Christian Evans Hughes v. State (2×)
Ga. Ct. App. · 2022 · confidence high
This conforms to the Supreme Court of Georgia’s explanation that “[a]s to sentencing, each count stands alone; thus, when a trial court considers the appropriate sentence for Count 1 of an indictment, it is the only criminal charge at issue, and not any other counts in the indictment.” Evans v. State, 300 Ga. 271, 276 ( 794 SE2d 40 ) (2016). 9 248 Ga. 183 ( 281 SE2d 604 ) (1981). 10 Id. at 185 (4), citing United States v. Benz, 282 U. S. 304 (51 SC 113, 75 LE 354) (1931), Higdon v. Cooper, 247 Ga. 746 ( 279 SE2d 451 ) (1981), overruled by Wilford v. State, 278 Ga. 718, 721, n.14 ( 606 SE…
discussed Cited "but see" State v. Hardesty (2×)
Wash. · 1996 · signal: but see · confidence high
Cir. 1987); United States v. Earley, 816 F.2d 1428, 1433 (10th Cir. 1987) (court could not correct sentence five months after rendering it); United States v. Arrellano-Rios, 799 F.2d 520, 524 (9th Cir. 1986) (expectation of finality arises upon completion of sentence); State v. Gaddy, 110 N.M. 120 , 792 P.2d 1163 (Ct. App. N.M. 1990); State v. Carvajal, 147 Ariz. 307, 310 , 709 P.2d 1366, 1369 (1985) (majority of cases holds the double jeopardy clause does not bar subsequent resentencing "where a defendant through fraud or collusion actively engineered an inadequate sentence”); but see Higdo…
discussed Cited "but see" State v. Hardesty (2×)
Wash. · 1996 · signal: but see · confidence high
In United States v. Jones, 722 F.2d 632, 638 (11th Cir.1983), the court stated a defendant has an expectation of finality in the sentence once she or he begins to serve it, unless a review process is employed or the defendant "intentionally deceive[d] the sentencing authority or thwart[ed] the sentencing process." See United States v. Daddino, 5 F.3d 262, 265 (7th Cir.1993) (legitimate expectation of finality in completed sentence); United States v. Rico, 902 F.2d 1065, 1068 (2d Cir.) (no expectation of finality where sentence is served but time for review has not expired), cert. denied, 498 U…
discussed Cited as authority (rule) Stanli Owens v. State
Ga. Ct. App. · 2014 · confidence medium
About 40 seconds later, the front seat passenger and an officer walked to that same door of Officer Pugh’s vehicle; the officer opened the door of the patrol vehicle, as the front seat passenger stood on 2 Walker v. State, 247 Ga. 746, 748-749 (2) ( 280 SE2d 333 ) (1981), citing Jackson, supra. After his convictions for possession of methamphetamine, driving while his license was suspended, and driving a vehicle with defective equipment, Owens moved for a new trial, which the trial court denied. 2 the other side of the door.
discussed Cited "see" Harris v. State (2×)
Ga. Ct. App. · 1991 · signal: accord · confidence high
Thus, we find the legal principles expressed in England and Entrekin more persuasive in this instance. (c) It is a well-established rule that “once the defendant begins to serve his sentence it may not be increased.” England v. Newton, supra at 536, citing Inman v. State, 124 Ga. App. 190 ( 183 SE2d 413 ); accord Higdon v. Cooper, 247 Ga. 746 ( 279 SE2d 451 ); Howell v. State, 160 Ga. App. 562 ( 287 SE2d 573 ); compare Entrekin v. State, supra, with Turnipseed v. State, 147 Ga. App. 735 ( 250 SE2d 186 ).
discussed Cited "see, e.g." Castillo v. State (2×)
Ga. Ct. App. · 1986 · signal: see also · confidence low
See also Higdon v. Cooper, 247 Ga. 746 ( 279 SE2d 451 ) (1981).
discussed Cited "see, e.g." McClinic v. State (2×)
Ga. Ct. App. · 1984 · signal: see also · confidence low
See also Higdon v. Cooper, 247 Ga. 746 ( 279 SE2d 451 ) (1981); Henderson v. State, 162 Ga. App. 320 (5) ( 292 SE2d 77 ) (1982).
Higdon
v.
Cooper
37538.
Supreme Court of Georgia.
Jun 30, 1981.
279 S.E.2d 451
Thomas J. Killeen, for appellant., Arthur K. Bolton, Attorney General, Michael R. Johnson, Assistant Attorney General, for appellee.
Undercofler, Jordan, Marshall.
Cited by 12 opinions  |  Published
Undercofler, Justice.

On June 1,1979, Higdon entered a guilty plea to burglary. Under a mistake that Higdon was a first offender, the trial court sentenced him to two years on probation, said probation conditioned upon successful completion of the “Gateway House” program. Higdon was confined under this sentence. Later it was discovered Higdon was not a first offender and on June 15,1979, the trial court revoked the two year probated sentence and Higdon was sentenced to five years confinement. The trial court found that, “. . . Higdon acted in conscious deceit and misrepresentation as to his apparent lack of prior convictions in that he not only remained silent as the District Attorney stated that said Higdon had no prior record. ...”

Higdon’s writ of habeas corpus was denied and he is here on appeal. We reverse. The law is clear. Once a defendant begins to serve his sentence it may not be increased. England v. Newton, 238 Ga. 534, 536 (233 SE2d 787) (1977).

Judgment reversed.

All the Justices concur, except Jordan, C. J,, and Marshall, J., who concur in the judgment only.