United States of America v. Mark a Morgan’s Empirical Analysis
230 F.3d 1067 · 2000
Citation profile
14 federal appellate · 3 district · 3 state decisions
How this case has been cited
Cited by 27 later decisions (1 by the Supreme Court) — most recently January 2025 · most notably United States v. Lipscomb (2002), United States v. Suarez (2001)
14 federal appellate · 3 district · 3 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 Stone v. Powell · Bailey v. United States · Schlup v. Delo · Tollett v. Henderson · Bousley v. United States
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Congress did not contract with states or local governments. Neither did Congress bestow gifts of funds upon those governments. Rather, Congress passed a federal criminal statute designed to punish conduct that falls within the domain of traditional state concerns (bribery, embezzlement, fraud, etc.). Section 666 reaches beyond punishment of the state and local governments who receive those funds to proscribe the conduct of third persons who aren’t parties to the funding contract.”
2 later decisions quote this exact passage · from the dissent“[a]s a general rule, “[a] defendant’s knowing and intelligent guilty plea forecloses ‘independent claims relating to the deprivation of constitutional rights that occurred before the entry of the guilty plea.’ ” United States v. Vaughan, 13 F.3d 1186, 1187 (8th Cir.[1994]) (quoting Tollett v. Henderson, 411 U.S. 258, 267 , 93 S.Ct. 1602, 1608 , 36 L.Ed.2d 235 (1973)), cert. denied, Vaughan v. U.S., 511 U.S. 1094 , 114 S.Ct. 1858 , 128 L.Ed.2d 481 (U.S. 1994). There are exceptions to this rule, however; a person may, despite a valid guilty plea, pursue a certain type of claim that has been variously defined as a claim that attacks “the State’s power to bring any indictment at all,” United States v. Broce, 488 U.S. 563, 575 , 109 S.Ct. 757, 765 , 102 L.Ed.2d 927 (1989), that protects a defendant’s “right not to be haled into court,” Blackledge v. Perry, 417 U.S. 21, 30 , 94 S.Ct. 2098, 2104 , 40 L.Ed.2d 628 (1974), and that “the charge is one which the State may not constitutionally prosecute,” Menna v. New York, 423 U.S. 61 , 62-63 n. 2, 96 S.Ct. 241 , 242 n. 2, 46 L.Ed.2d 195 (1975) (per curiam).”
1 later decision quote this exact passage · from the majoritye.g. State v. Andrews“A claim that a statute is facially unconstitutional falls within the exception. See Sodders v. Parratt, 693 F.2d 811, 812 (8th Cir.1982) (holding guilty plea does not foreclose attack on constitutionality of criminal statute under which defendant was charged-defendant claimed statute was vague on its face); United States v. Johnston, 199 F.3d 1015 , 1019 n. 3 (9th Cir.1999). [However, n]o court has applied the exception to a claim, like [appellant’s], that a statute is unconstitutional as applied. See Johnston, 199 F.3d at 1019 n. 3.”
1 later decision quote this exact passage · from the majoritye.g. State v. Andrews
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.