Waller v. Georgia’s Empirical Analysis
1984
Citation profile
718 federal appellate · 94 district · 1,709 state decisions
How this case has been cited
Cited by 3,154 later decisions (30 by the Supreme Court) — most recently March 2026 · most notably Arizona v. Fulminante (1991), Johnson v. United States (1997)
718 federal appellate · 94 district · 1,709 state decisions — followed in 46 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
Relies on Jackson v. Denno · In re Oliver · Richmond Newspapers, Inc. v. Virginia · Estes v. Texas
Cited together with Press-Enterprise Company v. Superior Court of California Riverside County · Arizona v. Fulminante · In re Oliver · Gideon v. Wainwright · Tumey v. State of Ohio
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 3,154 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The presumption of openness may be overcome only by an overriding interest based on findings that closure is essential to preserve higher values and is narrowly tailored to serve that interest. The interest is to be articulated along with findings specific enough that a reviewing court can determine whether the closure order was properly entered.”
95 later decisions quote this exact passage · from the dissent“[T]he party seeking to close the hearing must advance an overriding interest that is likely to be prejudiced, the closure must be no broader than necessary to protect that interest, the trial court must consider reasonable alternatives to closing the proceeding, and it must make findings adequate to support the closure.”
79 later decisions quote this exact passage · from the dissent“[1] the party seeking to close the hearing must advance an overriding interest that is likely to be prejudiced, [2] the closure must be no broader than necessary to protect that interest, [3] the trial court must consider reasonable alternatives to closing the proceeding, and [4] it must make findings adequate to support the closure.”
69 later decisions quote this exact passagee.g. Ayala v. Speckard · Brown v. Artuz
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.