Public-domain · open source
OpenJurist
← 381 U.S. 131 - Holt v. Commonwealth of Virginia

Holt v. Commonwealth of Virginia’s Empirical Analysis

1965

Citation profile

179
cited by 179 later decisions
7
cited 7 times by the Supreme Court
22
states following
December 2025
most recently cited

34 federal appellate · 3 district · 112 state decisions

How this case has been cited

Cited by 179 later decisions (7 by the Supreme Court) — most recently December 2025 · most notably In the Matter of Larry Little (1972), Roland M. v. Concord School Committee (1990)

34 federal appellate · 3 district · 112 state decisions — followed in 22 states

6101965197019801990200020102020decided

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

Relies on Gideon v. Wainwright · Irvin v. Dowd · Tumey v. State of Ohio · In the Matters of Lee Roy Murchison and John Whites · In re Oliver

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 179 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The right to be heard must necessarily embody a right to file motions and pleadings essential to present claims and raise relevant issues. And since '[a] fair trial in a fair tribunal is a basic requirement of due process,' ... motions for change of venue to escape a biased tribunal raise constitutional issues both relevant and essential.”
    5 later decisions quote this exact passage · from the majority
  2. ““3. That the said Judge Carlton E. Holladay, who presided as Judge in said libel suit, and who fails and refuses to disqualify himself as Judge in the pending trial of the Defendant, E. A. Dawley, Jr., has, with respect to said contempt action and is now in effect and/or in fact acting as police officer, chief prosecution witness, adverse witness for the defense, grand jury, chief prosecutor and judge. “4. That in addition to the foregoing, said Judge Carlton E. Holladay did intimidate and harass and is intimidating and harassing the lawyer representing said E. A. Dawley, Jr., viz, Leonard W. Holt, Esq., the effect of which is to seriously hamper the efforts of said Leonard W. Holt in defending the said E. A. Dawley, Jr.; that said harassment and intimidation arises out of and is connected solely with said Leonard W. Holt’s participating in the defense of said E. A. Dawley, Jr. in the contempt action; that part of said harassment and intimidation occurred at a hearing of this contempt action in the Hopewell Circuit Court on January 8, 1962, at which hearing the said Carlton E. Holladay revealed that he had been making an independent investigation and inquiry of Mr. Holt's conduct in this contempt defense, and said Judge at said place and time made the statement that he would ‘deal with’ said Leonard W. Holt after he, the judge, had dealt with said E. A. Dawley, Jr.” Id. at 133 .”
    1 later decision quote this exact passage · from the majority
  3. “[the state’s] apparent contention [is] that the contempt convictions should be sustained on the ground that petitioners' charges of bias were false. The truth or falsity of these charges was not heard, the trial court choosing instead to convict and sentence petitioners for having done nothing more than making the charges. Even if failure to prove their allegations of bias could under any circumstances ever be made part of the basis of a contempt charge against petitioners, these convictions cannot rest on any such unproven assumption. Our conclusion is that these petitioners have been punished by [the state] for doing nothing more than exercising the constitutional right of an accused and his counsel in contempt cases such as this to defend against the charges made.”
    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.