United States v. Ward’s Empirical Analysis
37 F.3d 243 · 1994
Citation profile
30 federal appellate · 1 district ·
How this case has been cited
Cited by 46 later decisions (1 by the Supreme Court) — most recently April 2018 · most notably Rutledge v. United States (1996), United States v. Delgado (2012)
30 federal appellate · 1 district ·
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 21 U.S.C. § 846 (§ 406 of the Controlled Substances Act) · 21 U.S.C. § 848 (§ 408 of the Controlled Substances Act)
Relies on Cities of Charlottesville v. Official Committee of Unsecured Creditors of Columbia Gas Transmission Corp. · Sowashee Venture v. EB, Inc. · Jeffers v. United States · United Transportation Union v. Southeastern Pennsylvania Transportation Authority · Carolco Television Inc. v. National Broadcasting Co.
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'simply purchasing cocaine from the 'organizer' standing alone is not enough to satisfy the relationship requirement.' " Ward, 37 F.3d at 247 (quoting United States v. English, 925 F.2d 154 , 157 (6th Cir.1991)). Further, " 'the mere 'fronting' of cocaine alone is insufficient to support finding a management relationship.' " Id. at 248 (quoting United States v. Possick, 849 F.2d 332 , 336 (8th Cir.1988)) (emphasis supplied). "Fronting cocaine, without additional elements of control, is nothing more than a variation on the traditional buyer-seller relationship.”
2 later decisions quote this exact passage · from the majority“(1) a felony violation of a federal narcotics law; (2) as part of a 'continuing series of violations;' (3) 'in concert with five or more persons;' (4) for whom defendant is an organizer or supervisor; and (5) from which he derives substantial income.”
2 later decisions quote this exact passage · from the majority“the jury need not unanimously agree on the identities of the five particular persons, nor need the five persons be named in the indictment or bill of particulars. A person can be found to be under the defendant’s organization or supervision because she knew about the drug operation, took orders directly from the defendant and helped in the drug business. A broker or courier under the defendant’s supervision, someone who stores drugs for the defendant, or one who collects or launders drug proceeds is also within the ambit of the statute.”
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.