Cramer v. United States’s Empirical Analysis
325 U.S. 1 · 1945
Citation profile
189 federal appellate · 20 district · 61 state decisions
How this case has been cited
Cited by 373 later decisions (62 by the Supreme Court) — most recently June 2025 · most notably New York Times Co. v. Sullivan (1964), Morissette v. United States (1952)
189 federal appellate · 20 district · 61 state decisions — followed in 14 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
reviewedUnited States v. Cramer (from Second Circuit Court of Appeals)
Relationships
Applies 18 U.S.C. § 1 · 50 U.S.C. § 31 · 50 U.S.C. § 4303
Relies on Stromberg v. People of State of California · Williams v. State of North Carolina · Quirin Haupt Kerling Burger Heinck Thiel Neubauer United States Quirin v. Cox Usa 6 · Ex Parte Bollman and Ex Parte Swartwout
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 373 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[w]hat a man is up to may be clear from considering his bare acts by themselves....”
4 later decisions quote this exact passage · from the majority“What is designed in the mind of an accused never is susceptible of proof by direct testimony. If we were to hold that the disloyal and treacherous intention must be proved by the direct testimony of two witnesses, it would be to hold that it is never provable. . Since intent must be inferred from conduct of some sort, we think it is permissible to draw usual reasonable inferences as to intent from the overt acts. The law of treason, like the law of lesser crimes, assumes every man to intend the natural consequences which one standing in his circumstances and possessing his knowledge would reasonably expect to result from his acts.”
3 later decisions quote this exact passage · from the majority““Treason against the United States, shall consist only in levying War against them, or in adhering to their Enemies, giving them Aid and Comfort. No Person shall be convicted of Treason unless on the Testimony of two Witnesses to the same overt Act, or on Confession in open Court.” Article III, § 3.”
3 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.