People v. Gallardo’s Empirical Analysis
1969
Citation profile
26 state decisions
How this case has been cited
Cited by 28 later decisions — most recently December 1983 · most notably 13 Cal. 3d 663 - People v. Cook (1975), 35 Cal. 3d 86 - People v. Mroczko (1983)
26 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 Chapman v. State of California · Glasser v. United States · Malinski v. People of State of New York · Local Union No. 12 v. National Labor Relations Board · People v. Massie
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The right to counsel at trial guaranteed by the Sixth Amendment of the United States Constitution ( Gideon v. Wainwright (1963) 372 U.S. 335 [ 9 L.Ed.2d 799 , 83 S.Ct. 792 , 93 A.L.R.2d 733 ]) and article I, section 13 of the California Constitution does not include an automatic right to separate counsel for each codefendant. One counsel may represent more than one defendant so long as the representation is effective. ( Powell v. Alabama (1932) 287 U.S. 45, 71 [ 77 L.Ed. 158, 171-172 , 53 S.Ct. 55 , 84 A.L.R. 527 ].) [3] Effective assistance of counsel is assistance `untrammeled and unimpaired by a court order requiring that one lawyer shall simultaneously represent conflicting interests.' ( Glasser v. United States (1942) 315 U.S. 60, 70 [ 86 L.Ed. 680, 699 , 62 S.Ct. 457 ]; People v. Douglas (1964) 61 Cal.2d 430, 437 [ 38 Cal. Rptr. 884 , 392 P.2d 964 ].) If counsel must represent conflicting interests or is ineffective because of the burdens of representing more than one defendant, the injured defendant has been denied his constitutional right to effective counsel. ( United States v. Glasser, supra ; People v. Robinson (1954) 42 Cal.2d 741, 745-748 [ 269 P.2d 6 ]; People v. Lanigan (1943) 22 Cal.2d 569, 576-577 [ 140 P.2d 24 , 148 A.L.R. 176 ]; People v. Douglas, supra ; People v. Donohoe (1962) 200 Cal. App.2d 17, 24 [ 19 Cal. Rptr. 454 ].)”
1 later decision quote this exact passage · from the concurrence““[I]t is usually the very error of not appointing separate counsel which makes it so difficult for the defendants to point to tangible evidence of prejudice.””
1 later decision quote this exact passage“... the facts of the case are fraught with potentially effective individual defenses,”
1 later decision quote this exact passage · from the concurrence
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.