29 F. Supp. 2d 292 - United States v. Lawhorne’s Empirical Analysis
1998
Citation profile
2 federal appellate · 4 state decisions
How this case has been cited
Cited by 9 later decisions — most recently March 2013
2 federal appellate · 4 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
Applies 18 U.S.C. § 3161 (§ 101 of the Speedy Trial Act of 1974) · 18 U.S.C. § 922 (Brady Handgun Violence Prevention Act)
Relies on United States v. Olano · Johnson v. Zerbst · Gideon v. Wainwright · Arizona v. Fulminante · Johnson 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Wjhether categorized as improper juror contact or juror bias, Lawhorne’s trial was infected by deviation from a legal rule, namely the Sixth Amendment right to trial by an impartial jury. Communications with, and bias in favor of, the prosecutor in a criminal case are evidence tending to show that the Juror likely reached a verdict on grounds other than the trial evidence. This is an error of the most fundamental sort and there can be no serious doubt that it falls within the reach of the term “error” under Rule 52(b).”
1 later decision quote this exact passage · from the concurrence“Second, it is necessary to determine whether there has been diligence on the part of the defendant. “Diligence” means ordinary diligence, not the highest degree thereof; and diligence usually is determined by taking into account the composite knowledge of the defendant and his counsel.”
1 later decision quote this exact passage · from the majoritye.g. State v. Stevens“Numerous decisions recognize that district courts are permitted to engage in plain error review and to determine whether a flaw in criminal proceedings was so patent as to warrant a new trial despite the absence of a timely objection by defense counsel.”
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.