Lamb v. Beto’s Empirical Analysis
423 F.2d 85 · 1970
Citation profile
44 federal appellate · 10 state decisions
How this case has been cited
Cited by 80 later decisions — most recently February 2007 · most notably Wilbert Herring v. W. J. Estelle, Director, Texas Department of Corrections (1974), Colson v. Smith (1971)
44 federal appellate · 10 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 Costello v. United States · Page v. Work · MacKenna v. Ellis · Edwards v. United States · Brown v. Beto
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 80 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It must be realized that this is not a case in which proof of guilt depended upon a trial. In such cases the accused usually relies to a great extent on counsel to conduct an effective defense, because the accused does not know enough of the law to do so himself . . . but this is not so when he pleads guilty. Here the deed is his own; here there are not the baffling complexities which require a lawyer for illumination; if voluntarily and understandingly made, even a layman should expect a plea of guilty to be treated as an honest confession of guilt and a waiver of all defenses known and unknown. And such is the law.””
2 later decisions quote this exact passage · from the majority“the only required duty of counsel under the most liberal construction when a plea of guilty is entered is that counsel . . . should ascertain if the plea is entered voluntarily and knowingly.”
2 later decisions quote this exact passage · from the majority“Reasonably effective assistance is an easier standard to meet in the context of a guilty plea than in a trial, but counsel still must render competent service ... It is the lawyer’s duty to ascertain if the plea is entered voluntarily and knowingly ... He must actually and substantially assist his client in deciding whether to plead guilty ... It is his job to provide the accused an ‘understanding of the law in relation to the facts’ ... The advice he gives need not be perfect, but it must be reasonably competent . .. His advice should permit the accused to make an informed and conscious choice ... In other words, if the quality of counsel’s service falls below a certain minimum level, the client’s guilty plea cannot be knowing and voluntary because it will not represent an informed choice.”
1 later decision quote this exact passage · from the majoritye.g. McBryar v. McElroy
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.