Parker v. Randolph’s Empirical Analysis
1979
Citation profile
274 federal appellate · 24 district · 640 state decisions
How this case has been cited
Cited by 1,193 later decisions (25 by the Supreme Court) — most recently February 2026 · most notably Crawford v. Washington (2004), Rose v. Clark (1986)
274 federal appellate · 24 district · 640 state decisions — followed in 39 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
reviewedRandolph v. Parker (from Sixth Circuit Court of Appeals)
Relationships
Relies on Miranda v. State of Arizona Vignera · Chapman v. State of California · Bruton v. United States · Edelman v. Jordan · Chambers v. Mississippi
Cited together with Bruton v. United States · Cruz v. New York · Harrington v. California · Chapman v. State of California · Lee v. Illinois
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 1,193 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'[t]he Confrontation Clause has never been held to bar the admission into evidence of every relevant extrajudicial statement made by a nontestifying declarant simply because it in some way incriminates the defendant'”
17 later decisions quote this exact passage · from the dissent“The fact that confessions may interlock to some degree does not ensure, as a per se matter, that their admission will not prejudice a defendant so substantially that a limiting instruction will not be curative. The two confessions may interlock in part only. Or they may cover only a portion of the events in issue at the trial. Although two interlocking confessions may not be internally inconsistent, one may go far beyond the other in implicating the confessor’s codefendant. In such circumstances, the admission of the confession of the codefendant who does not take the stand could very well serve to prejudice the defendant who is incriminated by the confession, notwithstanding that the defendant’s own confession is, to an extent, interlocking. I fully recognize that in most interlocking confession cases, any error in admitting the confession of a nontestifying codefendant will be harmless beyond a reasonable doubt. Even so, I would not adopt a rigid per se rule that forecloses a court from weighing all the circumstances in order to determine whether the defendant in fact was unfairly prejudiced by the admission of even an interlocking confession. Where he was unfairly prejudiced, the mere fact that prejudice was caused by an interlocking confession ought not to override the important interests that the Confrontation Clause protects.”
8 later decisions quote this exact passage · from the concurrence“"Not only are the incriminations [of a co-defendant's confession] devastating to a defendant but their credibility is inevitably suspect, a fact recognized when accomplices do take the stand and the jury is instructed to weigh their testimony carefully given the recognized motivation to shift blame onto others."”
7 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.