Ungar v. Sarafite’s Empirical Analysis
1964
Citation profile
1,147 federal appellate · 64 district · 1,506 state decisions
How this case has been cited
Cited by 3,429 later decisions (33 by the Supreme Court) — most recently March 2026 · most notably Withrow v. Larkin (1975), Morris v. Slappy (1983)
1,147 federal appellate · 64 district · 1,506 state decisions — followed in 48 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
Applies 28 U.S.C. § 2103
Relies on Tumey v. State of Ohio · In the Matters of Lee Roy Murchison and John Whites · In re Oliver · Offutt v. United States
Cited together with Morris v. Slappy · Avery v. State of Alabama · Strickland v. Washington · Powell v. State of Alabama Patterson · Glasser v. United States
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 3,429 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“There are no mechanical tests for deciding when a denial of a continuance is so arbitrary as to violate due process. The answer must be found in the circumstances present in every case, particularly in the reasons presented to the trial judge at the time the request is denied.”
206 later decisions quote this exact passage · from the majority“an insulting attack upon the integrity of the judge carrying such potential for bias as to require disqualification.”
19 later decisions quote this exact passage · from the majoritye.g. In re Kendall · Sandstrom v. State“[T]he inquiry must be not only whether there was actual bias on [the judge's] part, but also whether there was 'such a likelihood of bias or an appearance of bias that the judge was unable to hold the balance between vindicating the interests of the court and the interests of the accused.'”
11 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.