Edwards v. United States’s Empirical Analysis
256 F.2d 707 · 1958
Citation profile
162 federal appellate · 25 district · 74 state decisions
How this case has been cited
Cited by 310 later decisions (1 by the Supreme Court) — most recently February 2018 · most notably Commonwealth Ex Rel. Washington v. Maroney (1967), David Busby v. William C. Holman, Warden, Kilby Prison (1966)
162 federal appellate · 25 district · 74 state decisions — followed in 16 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
Applies 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Von Moltke v. Gillies · Mallory v. United States · Waley v. Johnston · Smith v. O'Grady · Howard 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 310 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““But there was much counsel might have done, appellant now tells us. Counsel might have argued the illegality of the arrest and might have moved to suppress evidence obtained by illegal search and seizure, and illegal confessions. We agree that counsel might have done these things, and perhaps, guided by hindsight, other things; but we do not agree that failure to do so was such ineffective assistance of counsel as to warrant a new trial. But we need not rest our decision on this ground, for an even stronger ground is available. “It must be realized that this is not a case in which proof of guilt depended upon a trial. In such cases, the accused usually relies to a great extent on counsel to conduct an effective defense, because the accused does not know enough of the law to do so himself. While the accused may have to take the consequences of a poor defense, he may at least say the fault was not his own. But this is not so when he pleads guilty. Here the deed is his own; here there are not the baffling complexities which require a lawyer for illumination; if voluntarily and understandingly made, even a layman should expect a plea of guilty to be treated as an honest confession of guilt and a waiver of all defenses known and unknown. And such is the law. A plea of guilty may not be withdrawn after sentence except to correct a ‘manifest injustice,’ and we find it difficult to imagine how ‘manifest injustice’ could be shown except by proof that the plea was not voluntarily or u”
19 later decisions quote this exact passage · from the majority““ * * * Mere improvident strategy, bad tactics, mistake, carelessness or inexperience do not necessarily amount to ineffective assistance of counsel, unless taken as a whole the trial was a ‘mockery of justice.’ * * * ””
1 later decision quote this exact passage · from the majoritye.g. State v. Moser
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.