Shawn Ian Lainfiesta v. Christopher Artuz, Superintendent, Greenhaven Corr. Facility Elliot Spitzer, Attorney General’s Empirical Analysis
253 F.3d 151 · 2001
Citation profile
20 federal appellate · 2 district · 3 state decisions
How this case has been cited
Cited by 73 later decisions (1 by the Supreme Court) — most recently September 2023 · most notably David Aparicio v. Christopher Artuz (2001), Cotto v. Herbert (2003)
20 federal appellate · 2 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 Strickland v. Washington · Williams v. Taylor · Faretta v. California · Gideon v. Wainwright · Kotteakos 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 73 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A state court decision falls within the unreasonable application clause if the state court identifies the correct governing legal principle from [the Supreme Court’s] decisions but unreasonably applies that principle to the facts of the prisoner’s case. The Supreme Court has thus far offered little guidance as to the meaning of the term unreasonable application, tautologically instructing federal habeas courts to ask whether the state court’s application was objectively unreasonable. The Supreme Court did caution, however, that an unreasonable application of federal law is different from an incorrect or erroneous application of federal law. Thus, a federal habeas court is not empowered to grant the writ when, in its independent judgment, it determines that the state court incorrectly applied the relevant federal law. The state court’s application must reflect some additional increment of incorrectness such that it may be said to be unreasonable. However, the increment need not be great; otherwise, habeas relief would be limited to state court decisions so far off the mark as to suggest judicial incompetence.”
3 later decisions quote this exact passage · from the majority“In sum, the statute directs federal courts to attend to every state-court judgment with utmost care, but it does not require them to defer to the opinion of every reasonable state-court judge on the content of federal law. If, after carefully weighing all the reasons for accepting a state-court’s judgment a federal court is convinced that a prisoner’s custody ... violates the Constitution, that independent judgment should prevail. Otherwise the federal law as determined by the Supreme Court of the United States might be applied by the federal courts one way in Virginia and another way in California.”
1 later decision quote this exact passage · from the majority“The Supreme Court has held that violations of the Sixth Amendment right to counsel are per se reversible only when they amount to an actual or constructive denial of the assistance of counsel altogether, or when counsel was prevented from assisting the accused during a critical stage of the proceeding.”
1 later decision quote this exact passage · from the majoritye.g. Dallio v. Spitzer
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.