United States v. Mitchell’s Empirical Analysis
322 U.S. 65 · 1944
Citation profile
655 federal appellate · 42 district · 281 state decisions
How this case has been cited
Cited by 1,091 later decisions (19 by the Supreme Court) — most recently June 2014 · most notably Miranda v. State of Arizona Vignera (1966), Culombe v. Connecticut (1961)
655 federal appellate · 42 district · 281 state decisions — followed in 35 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.
Appellate journey
reviewedMitchell v. United States (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on McNabb v. United States · Nardone v. United States · Wilson v. United States · United States v. Oppenheimer
Cited together with McNabb v. United States · Upshaw v. United States · Mallory v. United States · United States v. Carignan · Miranda v. State of Arizona Vignera
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 1,091 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““But in any event, the illegality of Mitchell’s detention does not retroactively change the circumstances under which he made the disclosures. These, we have seen, were not elicited through illegality. Their admission, therefore, would not be use by the Government of the fruits of wrongdoing by its officers. Being relevant, they could be excluded only as a punitive measure against unrelated wrongdoing by the police. Our duty in shaping rules of evidence relates to the propriety of admitting evidence. This power is not to be used as an indirect mode of disciplining misconduct.” [ 322 U.S. 65 , 64 S.Ct. 898 ]”
13 later decisions quote this exact passage · from the majority““Inexcusable detention for the purpose of illegally extracting evidence from an accused, and the successful extraction of such inculpatory statements by continuous questioning for many hours under psychological pressure, were the decisive features in the McNabb case which led us to rule that a conviction on such evidence could not stand.” 322 U.S. at 67, 64 S.Ct. at 897. (Emphasis added.)”
11 later decisions quote this exact passage · from the majority““As I understand McNabb v. United States, 318 U.S. 322 , 63 S.Ct. 608 , 87 L.Ed. 819 , as explained by the Court’s opinion of today, the Mc-Nabb rule is that where there has been illegal detention of a prisoner, joined with other circumstances which are deemed by this Court to be contrary to proper conduct of federal prosecutions, the confession will not be admitted. Further, this refusal of admission is required even though the detention plus the conduct do not together amount to duress or coercion. * * * ””
2 later decisions 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.