Brown v. Kuhlmann’s Empirical Analysis
142 F.3d 529 · 1998
Citation profile
23 federal appellate · 1 district · 15 state decisions
How this case has been cited
Cited by 90 later decisions — most recently December 2023 · most notably State v. Drummond (2006), Ernest Sutton Bell v. Mack Jarvis Robert Smith (2000)
23 federal appellate · 1 district · 15 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 Strickland v. Washington · Gideon v. Wainwright · Wainwright v. Sykes · Brecht v. Abrahamson · Arizona v. Fulminante
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 90 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Our holding that the courtroom closure here was not error ... turns in large measure on the significance of the testimony during the closure itself. Specifically, this case did not involve the classic courtroom closure during the testimony of an undercover police officer who was a party to a buy-and bust drug transaction with the defendant. In such a case, the prosecution invariably centers around this witness: the undercover officer who purchased the drugs provides the only testimony as to the defendant’s identity as the seller. The only additional testimony is provided by the arresting officer and, in some cases, a police chemist. While [the officer] happened to have been an undercover officer when he testified, this case did not involve a drug transaction with the petitioner, nor did his testimony directly relate to the criminal activity for tuhich petitioner was charged. ... Under these circumstances, ... the closure did not violate the Public Trial Clause.”
4 later decisions quote this exact passage · from the majority“neither entirely accurate nor particularly compelling, the strength of the judge's findings must be evaluated by reference to the very limited scope of the closure that they support [and that] by that standard, the trial court's findings were adequate”
3 later decisions quote this exact passage · from the dissent“On the contrary, New York law guarantees a defendant a public trial, and the New York appellate courts have been particularly vigilant in correcting errors involving partial courtroom closures.”
2 later decisions quote this exact passage · from the dissent
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.