United States v. Bass’s Empirical Analysis
1971
Citation profile
2,162 federal appellate · 258 district · 342 state decisions
How this case has been cited
Cited by 3,812 later decisions (220 by the Supreme Court) — most recently May 2025 · most notably Will v. Michigan Department of State Police (1989), United States v. Lopez (1995)
2,162 federal appellate · 258 district · 342 state decisions — followed in 37 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.
Appellate journey
reviewedUnited States v. Bass (from Second Circuit Court of Appeals)
Relationships
Relies on Universal Camera Corp. v. National Labor Relations Board · Younger v. Harris · Bell v. United States · Tot v. United States
Cited together with Rewis v. United States · United States v. Lopez · Perez v. United States · Scarborough v. United States · Bell 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 3,812 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“where there is ambiguity in a criminal statute, doubts are resolved in favor of the defendant.”
109 later decisions quote this exact passage · from the majority“In traditionally sensitive areas, such as legislation affecting the federal balance, the requirement of clear statement assures that the legislature has in fact faced, and intended to bring into issue, the critical matters involved in the judicial decision.”
75 later decisions quote this exact passage · from the majority“• . . a person “possesses . . . in commerce or affecting commerce” if at the time of the offense the gun was moving interstate or on an interstate facility, or if the possession affects commerce. Significantly broader in reach, however, is the offense of “receiv[ing] ... in commerce or affecting commerce,” for we conclude that the Government meets its burden here if it demonstrates that the firearm received has previously traveled in interstate commerce.”
25 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.