Georcely v. Ashcroft’s Empirical Analysis
375 F.3d 45 · 2004
Citation profile
23 federal appellate ·
How this case has been cited
Cited by 32 later decisions — most recently February 2023 · most notably Mukamusoni v. Ashcroft (2004), Sorcia v. Holder (2011)
23 federal appellate ·
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 28 U.S.C. § 1291 · 28 U.S.C. § 1406 · 48 U.S.C. § 1613A · 8 U.S.C. § 1101 (§ 101 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1182 (§ 212 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1229A (§ 240 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1252 (§ 242 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1252B (§ 242b of the Immigration and Nationality Act of 1952 (McCarran-Walter))
Relies on Strickland v. Washington · LOZADA · Atkins v. Parker · 118 S. Ct. 335 - Gens v. Federal Deposit Insurance · Lozada v. Immigration & Naturalization Service
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]f freely indulged, ineffective assistance claims would undermine the stringent requirements of section 1229a(b)(5)(C) (and much else in the statute besides) so the BIA has insisted that the alien has to comply with the procedural requirements of Matter of Lozada, 19 I. & N. Dec. 637 [ 1988 WL 235454 ] (BIA 1988). These include the filing of a bar complaint against counsel or adequately explaining why the complaint has not been filed. * * * The present case is a perfect example. A claim of inadequate representation has not been squarely made either before the [BIA] or on this appeal. Counsel has sought to make his own carelessness, if that is the proper characterization, an excuse for Georcely’s failure to appear, while never conceding that his own conduct as counsel was ineffective representation — a standard that requires a showing of significant incompetence and a likely adverse effect on the ultimate outcome.”
1 later decision quote this exact passagee.g. Komi v. Gonzales“belatedly made on the eve of a scheduled argument”
1 later decision quote this exact passage
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.