United States v. Willis’s Empirical Analysis
38 F.3d 170 · 1994
Citation profile
41 federal appellate · 2 district · 8 state decisions
How this case has been cited
Cited by 74 later decisions (1 by the Supreme Court) — most recently July 2025 · most notably Dixon v. United States (2006), United States v. Flores (1995)
41 federal appellate · 2 district · 8 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
Relies on Strickland v. Washington · United States v. Bailey · Blanton v. General Electric Credit Corp. · Kashif v. United States · Hughey 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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) that the defendant or a member of his family was under an unlawful and present, imminent, and impending threat of such a nature as to induce a well-grounded apprehension of death or serious body injury; (2) that he did not recklessly or negligently place himself in a situation in which it was probable that he would be forced to choose the criminal conduct; (3) that he had no reasonable legal alternative to violating the law, that is, he had no chance to refuse to do the criminal act and to avoid the threatened harm; and (4) that there was a direct causal relationship between the criminal action taken and the avoidance of the threatened harm.”
4 later decisions quote this exact passage · from the majority“[s]uch evidence is not addressed to whether a person of reasonable firmness would have succumbed to the level of coercion present in a given set of circumstances. Quite the contrary, such evidence is usually consulted to explain why this particular defendant succumbed when a reasonable person without a background of being battered might not have. Specifically, battered woman's syndrome evidence seeks to establish that, because of her psychological condition, the defendant is unusually susceptible to the coercion.”
3 later decisions quote this exact passage · from the majority“a justification defense such as duress is an affirmative defense, the burden of proof is on the defendant”
2 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.