Commonwealth v. Mahnke’s Empirical Analysis
1975
Citation profile
3 federal appellate · 191 state decisions
How this case has been cited
Cited by 195 later decisions — most recently July 2019 · most notably Commonwealth v. Bradshaw (1982), Commonwealth v. Haas (1977)
3 federal appellate · 191 state decisions — followed in 13 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
Relies on Miranda v. State of Arizona Vignera · Wong Sun v. United States · Schneckloth v. Bustamonte · Coolidge v. New Hampshire · Escobedo v. Illinois
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 195 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the first line of analysis, the court must look for a `break in the stream of events,' the coercive circumstances which extracted earlier statements, `sufficient to insulate the [subsequent] statement from the effect of all that went before.' Clewis v. Texas, [ 386 U.S. 707, 710 (1967)]. The focus of this line of analysis is on external constraints, continuing or new, which may have overborne the defendant's will. When circumstances no longer coerce the defendant, a break in the stream has occurred. The second line of analysis looks more specifically to the effect of the previous confession on the defendant's will. To be admissible, subsequent statements may not be `merely the product of the erroneous impression that the cat was already out of the bag' ( Darwin v. Connecticut, 391 U.S. 346, 351 [1968] [Harlan, J., concurring and dissenting]) because one coerced confession has let the secret `out for good.' United States v. Bayer, 331 U.S. 532, 540 (1947).”
1 later decision quote this exact passage · from the concurrence“Underlying the above-cited decisions is the fundamental recognition that a statement obtained through coercion and introduced at trial is every bit as offensive to civilized standards of adjudication when the coercion flows from private hands as when official depredations elicit a confession. Statements extracted by a howling lynch mob or a lawless private pack of vigilantes from a terrorized, pliable suspect are repugnant to due process mandates of fundamental fairness and protection against compulsory self-incrimination. ( 335 N.E.2d at 672 ).”
1 later decision quote this exact passage · from the concurrence“a defendant is entitled to lesser safeguards with respect to the admissibility of admissions and exculpatory statements than he would have if the statements had amounted to a confession,”
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.