Rose v. Lundy’s Empirical Analysis
1982
Citation profile
2,691 federal appellate · 674 district · 85 state decisions
How this case has been cited
Cited by 6,859 later decisions (145 by the Supreme Court) — most recently June 2025 · most notably Strickland v. Washington (1984), Slack v. McDaniel (2000)
2,691 federal appellate · 674 district · 85 state decisions — followed in 19 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
reviewedNational Labor Relations Board v. Garrard Convalescent Home, Inc. (from Sixth Circuit Court of Appeals)
Relationships
Relies on Miranda v. State of Arizona Vignera · Chapman v. State of California · Gideon v. Wainwright · Mapp v. Ohio · North Carolina v. Pearce
Cited together with Wainwright v. Sykes · Picard v. Connor · Strickland v. Washington · Engle v. Isaac · Coleman v. Thompson
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 6,859 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“teaches that one court should defer action on causes properly within its jurisdiction until the courts of another sovereignty with concurrent powers, and already cognizant of the litigation, have had an opportunity to pass upon the matter.”
100 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.”
98 later decisions quote this exact passage · from the majoritye.g. Butler v. Rose · Fleming v. Kemp“Because a rule requiring exhaustion of all claims furthers the purposes underlying the habeas statute, we hold that a district court must dismiss such “mixed petitions,” leaving the prisoner with the choice of returning to state court to exhaust his claims or of amending or resubmitting the habeas petition to present only exhausted claims to the district court.”
44 later decisions quote this exact passage · from the majoritye.g. Ray v. Moore · Zepeda v. Dorsey
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.