People v. Edney’s Empirical Analysis
1976
Citation profile
4 federal appellate · 50 state decisions
How this case has been cited
Cited by 70 later decisions — most recently March 2013 · most notably Bowne of New York City, Inc. v. AmBase Corp. (1993), State v. Pratt (1979)
4 federal appellate · 50 state decisions — followed in 12 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
Relies on People v. . Bloom · Capron v. . Douglass
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 70 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"When the patient first fully discloses the evidence of his affliction, it is he who has given the public the full details of his case, thereby disclosing the secrets which the statute was designed to protect, thus creating a waiver removing it from the operation of the statute; and once the privilege is thus waived, there is nothing left to protect against for once the revelation is made by the patient there is nothing further to disclose ‘for when a secret is out[J it is out for all time[,] and cannot be caught again like a bird, and put back in its cage.... The legislature did not intend to continue the privilege when there was no reason for its continuance and it would simply be an obstruction to public justice.’ ””
3 later decisions quote this exact passage“A defendant who seeks to introduce psychiatric testimony in support of his insanity plea may be required to disclose prior to trial the underlying basis of his alleged affliction to a prosecution psychiatrist. Hence, where, as here, a defendant reveals to the prosecution the very facts which would be secreted by the exercise of the privilege, reason does not compel the exclusion of expert testimony based on such facts, or cross-examination concerning the grounds for opinions based thereon. It follows that no harm accrues to the defense from seeking pretrial psychiatric advice where an insanity plea is actually entered, for in such circumstances, the underlying factual basis will be revealed to the prosecution psychiatrist. [People v. Edney, 39 N.Y.2d 620 , 350 N.E.2d 400, 403 , 385 N.Y.S.2d 23, 26 (1976) (citations omitted).]”
2 later decisions 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.