Towns v. Smith’s Empirical Analysis
395 F.3d 251 · 2005
Citation profile
34 federal appellate · 4 state decisions
How this case has been cited
Cited by 108 later decisions — most recently May 2025 · most notably Jells v. Mitchell (2008), Davis v. Lafler (2011)
34 federal appellate · 4 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
Relies on Strickland v. Washington · Williams v. Taylor · Wiggins v. Smith, Warden · Kimmelman v. Morrison · Roe, Warden v. Flores-Ortega
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 108 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Strategic choices made after less than complete investigation are reasonable precisely to the extent that reasonable professional judgments support the limitations on investigation. In other words, counsel has a duty to make reasonable investigations or to make a reasonable decision that makes particular investigations unnecessary. In any ineffectiveness case, a particular decision not to investigate must be directly assessed for reasonableness in all the circumstances, applying a heavy measure of deference to counsel’s judgments.”
4 later decisions quote this exact passage · from the majority“[Strategic choices made after thorough investigation of law and facts relevant to plausible options are virtually unchallengeable; and strategic choices made after less than complete investigation are reasonable precisely to the extent that reasonable professional judgments support the limitations on investigation. In other words, counsel has a duty to make reasonable investigations or to make a reasonable decision that makes particular investigations unnecessary.”
1 later decision quote this exact passage · from the majority“A purportedly strategic decision is not objectively reasonable when the attorney has failed to investigate his options and make a reasonable choice between them.”
1 later decision quote this exact passage · from the majoritye.g. Ramonez v. Berghuis
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.