Williams v. Bartlett’s Empirical Analysis
44 F.3d 95 · 1994
Citation profile
27 federal appellate · 1 district · 31 state decisions
How this case has been cited
Cited by 76 later decisions — most recently January 2025 · most notably 15 Cal. 4th 1 - People v. Marshall (1997), 184 Ill. 2d 1 - People v. Burton (1998)
27 federal appellate · 1 district · 31 state decisions — followed in 13 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
Applies 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Johnson v. Zerbst · Faretta v. California · McKaskle v. Wiggins · Brady v. United States · Bankers Life & Casualty Co. v. Crenshaw
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 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"[t]he purpose of requiring that a criminal defendant make an 'unequivocal' request to waive counsel is twofold. First, unless the request is unambiguous and unequivocal, a convicted defendant could have a colorable Sixth Amendment appeal regardless of how the trial judge rules: if his request is denied, he will assert the denial of his right to self-representation; if it is granted, he will assert the denial of his right to counsel. Second, the requirement of an unambiguous and unequivocal request inhibits any 'deliberate plot to manipulate the court by alternatively requesting, then waiving counsel' " ( Williams v. Bartlett, 44 F.3d 95 , 100-101 [2d Cir.1994] [internal citations omitted] ).”
6 later decisions quote this exact passage · from the majority“[A] defendant is not deemed to have equivocated in his desire for self-representation merely because he expresses that view in the alternative [and] simultaneously requests the appointment of new counsel . . . .”
3 later decisions quote this exact passage · from the majority“After trial has begun, a trial court faced with [a request to proceed pro se] must balance the legitimate interests of the defendant in self-representation against the potential disruption of the proceedings already in progress. . . . In exercising this discretion, the appropriate criteria for a trial judge to consider are the defendant's reasons for the self-representation request, the quality of counsel representing the party, and the party's prior proclivity to substitute counsel.”
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.