Rose v. Clark’s Empirical Analysis
1986
Citation profile
1,517 federal appellate · 47 district · 1,869 state decisions
How this case has been cited
Cited by 4,122 later decisions (76 by the Supreme Court) — most recently February 2026 · most notably United States v. Olano (1993), Brecht v. Abrahamson (1993)
1,517 federal appellate · 47 district · 1,869 state decisions — followed in 49 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
reviewedthe decision below (from Sixth Circuit Court of Appeals)
Relationships
Relies on Jackson v. Virginia · Chapman v. State of California · Batson v. Kentucky · In the Matter of Samuel Winship · Gideon v. Wainwright
Cited together with Chapman v. State of California · Arizona v. Fulminante · Sandstrom v. Montana · Delaware v. Van Arsdall · Sullivan v. Louisiana
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 4,122 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]f the defendant had counsel and was tried by an impartial adjudicator, there is a strong presumption that any other errors that may have occurred are subject to harmless-error analysis.”
247 later decisions quote this exact passage““[0]ur harmless error cases do not turn on whether the defendant conceded the factual issue on which the error bore. Rather, we have held that Chapman mandates consideration of the entire record prior to reversing a conviction for constitutional errors that may be harmless.””
9 later decisions quote this exact passage · from the dissent“beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.”
9 later decisions quote this exact passage · from the concurrence
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.