United States v. Combs’s Empirical Analysis
369 F.3d 925 · 2004
Citation profile
57 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 154 later decisions — most recently February 2025 · most notably Moldowan v. City of Warren (2009), United States v. Warshak (2010)
57 federal appellate · 1 district · 2 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. § 924 · 21 U.S.C. § 841 (§ 401 of the Controlled Substances Act) · 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Strickland v. Washington · Bailey v. United States · Reiter v. Sonotone Corp. · Smith v. United States · Tristani v. Eastern Air Lines, Inc.
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 154 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“COUNT THREE THE GRAND JURY FURTHER CHARGES: On or about April 26, 2005, in the Middle District of Tennessee, KENNETH L. JONES, knowingly used, carried, and discharged a firearm, to-wit: a Glock, Model 21, .45 caliber, semi-automatic pistol, during and in relation to a drug trafficking crime for which he may be prosecuted in a court of the United States, to-wit: a violation of Title 21, United States Code, Sections 846 and 841(a)(1). In violation of Title 18, United States Code, Section 924(c), and Title 18, United States Code, Section 2. COUNT FOUR THE GRAND JURY FURTHER CHARGES: On or about April 26, 2005, in the Middle District of Tennessee, THOMAS M. THOMPSON, knowingly used and carried a firearm, to-wit: a Ruger, Model P94, .40 caliber, semi-automatic pistol, during and in relation to a drug trafficking crime for which he may be prosecuted in a court of the United States, to-wit: a violation of Title 21, United States Code, Sections 846 and 841(a)(1). In violation of Title 18, United States Code, Section 924(c), and Title 18, United States Code, Section 2.”
2 later decisions quote this exact passage · from the majority“protects three constitutional due process rights, namely: the Sixth Amendment’s right to fair notice of the criminal charges against which one will need to defend; and the Fifth Amendment’s dual protections against twice placing a defendant in jeopardy for the same offense, and holding the defendant to answer for crimes not presented to or indicted by a grand jury. United States v. Combs, 369 F.3d 925 , 935 (6th Cir.2004) (quoting United States v. Pandilidis, 524 F.2d 644 , 648 (6th Cir.1975)). The grand jury is vested with the exclusive authority of setting the criminal charges in an indictment.”
2 later decisions quote this exact passage · from the majority“There are situations where a possession would be “during and in relation to” drug trafficking without “furthering or advancing” that activity. For example, a drug buyer might steal a gun from his dealer’s house during a deal. The buyer’s possession would be during and in relation to drug trafficking, but the buyer’s possession would not advance that operation. As another example, if a buyer came to the seller’s home for a purchase and left a gun there by mistake, the seller’s possession would be “during and in relation to” the trafficking without furthering it.”
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.