Fuller v. Oregon’s Empirical Analysis
1974
Citation profile
95 federal appellate · 22 district · 469 state decisions
How this case has been cited
Cited by 646 later decisions (13 by the Supreme Court) — most recently November 2025 · most notably Faretta v. California (1975), Board of Directors of Rotary International v. Rotary Club of Duarte (1987)
95 federal appellate · 22 district · 469 state decisions — followed in 35 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 Gideon v. Wainwright · Powell v. State of Alabama Patterson · Stanley v. Illinois · Griffin v. People of the State of Illinois · McGowan v. State of Maryland Gallagher
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 646 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The fact that an indigent who accepts state-appointed legal representation knows that he might someday be required to repay the costs of these services in no way affects his eligibility to obtain counsel.”
30 later decisions quote this exact passage · from the majority“(1) Repayment must not be mandatory; (2) Repayment may be imposed only on convicted defendants; (3) Repayment may only be ordered if the defendant is or will be able to pay; (4) The financial resources of the defendant must be taken into account; (5) A repayment obligation may not be imposed if it appears there is no likelihood the defendant's indigency will end; (6) The convicted person must be permitted to petition the court for remission of the payment of costs or any unpaid portion; (7) The convicted person cannot be held in contempt for failure to repay if the default was not attributable to an intentional refusal to obey the court order or a failure to make a good faith effort to make repayment.”
15 later decisions quote this exact passage · from the majoritye.g. Thomas v. Haslam · State v. Blank“"... "(2) Costs must be limited to reasonable compensation and costs incurred by the court-appointed counsel in the criminal proceeding. Costs may not include expenses inherent in providing a constitutionally guaranteed jury trial or expenditures in connection with the maintenance and operation of government agencies that must be made by the public irrespective of specific violations of law. "(3) The court may not sentence a defendant to pay the costs of court-appointed counsel unless the defendant is or will be able to pay them. In determining the amount and method of payment of costs, the court shall take account of the financial resources of the defendant and the nature of the burden that payment of costs will impose. "(4) A defendant who has been sentenced to pay costs and who is not in contumacious default in the payment thereof may at any time petition the court that sentenced him for remission of the payment of costs or of any unpaid portion thereof. If it appears to the satisfaction of the court that payment of the amount due will impose manifest hardship on the defendant or his immediate family, the court may remit all or part of the amount due in costs or modify the method of payment." (emphasis added)”
11 later decisions quote this exact passage · from the dissent
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.