United States v. Lyon’s Empirical Analysis
397 F.2d 505 · 1968
Citation profile
104 federal appellate · 1 district · 14 state decisions
How this case has been cited
Cited by 156 later decisions — most recently June 2025 · most notably United States v. Varelli (1969), United States v. Polizzi (1974)
104 federal appellate · 1 district · 14 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. § 2 · 18 U.S.C. § 3481 · 18 U.S.C. § 371
Relies on Chapman v. State of California · Bruton v. United States · Aguilar v. Texas · Jones v. United States · Griffin v. California
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 156 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“indirect references to a defendant's silence at trial violate the Fifth Amendment only if the 'language used was manifestly intended to be or was of such a character that the jury would naturally and necessarily take it to be a comment on the defendant's failure to testify.'”
11 later decisions quote this exact passage · from the majority“a defendant has the absolute right not to testify. The fact that the defendant did not testify should not be considered by you in any way in arriving at your verdict.”
2 later decisions quote this exact passage · from the majority“the natural and necessary effect of calling the attention of the jury to [the defendant's] failure to testify.”
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.