Edmonds v. United States’s Empirical Analysis
273 F.2d 108 · 1959
Citation profile
89 federal appellate · 55 state decisions
How this case has been cited
Cited by 155 later decisions (2 by the Supreme Court) — most recently April 2021 · most notably Harrison v. United States (1968), State v. Castonguay (1991)
89 federal appellate · 55 state decisions — followed in 22 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 18 U.S.C. § 4244
Relies on Green v. United States · Allen v. United States · Mallory v. United States · Milton 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 155 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Edmonds says the trial court erred in permitting parts of his testimony to be read to the jury at the second trial, at which he did not take the stand, although he admitted the accuracy of the transcript which was used. The reception of his statements at the prior trial violated his privilege against self-incrimination, it is argued. “It is generally held, unless a statute directs otherwise, that a defendant in a criminal case who takes the stand in his own behalf and testifies without asserting his privilege against self-incrimination thereby waives the privilege as to the testimony given so that it may be used against him in a subsequent trial of the same case. The fact that the defendant does not take the stand at the second trial does not prevent the use of his testimony given at the former trial, if it would otherwise be admissible. * * * ” (Italics added.)”
4 later decisions quote this exact passage · from the majority“[H]aving voluntarily gone on the witness stand in her own behalf on the former trial, and there made statements against her interest, it was entirely competent for the state, on the second trial, to prove those statements as admissions voluntarily made. Admissions made under such circumstances may be proven in the same manner and for the same reasons that admissions made out of court may be proven.”
1 later decision quote this exact passage · from the majoritye.g. Turner v. State“Evidence of flight is competent as having a tendency to establish guilt. Allen v. United States, 1896, 164 U.S. 492 , 499, 17 S.Ct. 154, 41 L.Ed. 528; Green v. United States, 1958, 104 U.S.App.D.C. 23, 25, 259 F.2d 180. * * *”
1 later decision 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.