Francis v. Henderson’s Empirical Analysis
1976
Citation profile
560 federal appellate · 73 district · 213 state decisions
How this case has been cited
Cited by 1,449 later decisions (75 by the Supreme Court) — most recently August 2023 · most notably Jackson v. Virginia (1979), Coleman v. Thompson (1991)
560 federal appellate · 73 district · 213 state decisions — followed in 22 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
reviewedJohn Newman v. C. Murray Henderson, Warden, Louisiana State Penitentiary, Abraham Francis v. C. Murray Henderson, Warden, Louisiana State Penitentiary (from Fifth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 2241 (Antiterrorism and Effective Death Penalty Act of 1996) · 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996) · 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Schneckloth v. Bustamonte · Johnson v. Zerbst · Barker v. Wingo · Younger v. Harris · Fay v. Noia
Cited together with Wainwright v. Sykes · Fay v. Noia · Davis v. United States · Engle v. Isaac · Stone v. Powell
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 1,449 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“considerations of comity and concerns for the orderly administration of criminal justice.”
21 later decisions quote this exact passage · from the majority“(b) An application for a writ of habeas corpus in behalf of a person in custody pursuant to the judgment of a State court shall not be granted unless it appears that the applicant has exhausted the remedies available in the courts of the State, or that there is either an absence of available State corrective process or the existence of circumstances rendering such process ineffective to protect the rights of the prisoner. (c) An applicant shall not be deemed to have exhausted the remedies available in the courts of the State, within the meaning of this section, if he has the right under the law of the State to raise, by any available procedure, the question presented.”
9 later decisions quote this exact passage · from the majority“not only a showing of 'cause' for the defendant's failure to challenge the composition of the grand jury before trial, but also a showing of actual prejudice.”
9 later decisions quote this exact passage · from the majoritye.g. Murray v. Carrier · Evans v. Maggio
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.