United States v. Bowie’s Empirical Analysis
232 F.3d 923 · 2000
Citation profile
59 federal appellate · 27 district · 29 state decisions
How this case has been cited
Cited by 144 later decisions — most recently November 2025 · most notably United States v. Cross (2002), United States v. Green (2010)
59 federal appellate · 27 district · 29 state decisions — followed in 13 states
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 Huddleston v. United States · Old Chief v. United States · United States v. Blakeney · United States v. Gibbs · United States v. Towne
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 144 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A defendant's bad act may be only tangentially related to the charged crime, but it nevertheless could "complete the story" or "incidentally involve" the charged offense or "explain the circumstances." If the prosecution's evidence did not "explain" or "incidentally involve" the charged crime, it is difficult to see how it could pass the minimal requirement for admissibility that evidence be relevant. . . . [A]ll relevant prosecution evidence explains the crime or completes the story. The fact that omitting some evidence would render a story slightly less complete cannot justify circumventing Rule 404(b) altogether. Moreover, evidence necessary to complete a storyfor instance by furnishing a motive or establishing identitytypically has a non-propensity purpose and is admissible under Rule 404(b). We see no reason to relieve the government and the district court from the obligation of selecting from the myriad of non-propensity purposes available to complete most any story.”
5 later decisions quote this exact passage · from the majoritye.g. State v. Berosik · State v. Fetelee“for other purposes, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.”
4 later decisions quote this exact passage · from the majority“evidence of other crimes, wrongs, or acts.”
4 later decisions quote this exact passage · from the majority
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.