United States v. Charles Thomas Bryan and James Eston Echols. Appeal of Charles Thomas Bryan’s Empirical Analysis
483 F.2d 88 · 1973
Citation profile
50 federal appellate · 1 district · 4 state decisions
How this case has been cited
Cited by 64 later decisions — most recently February 2025 · most notably United States v. Bell (1982), United States v. Pungitore (1990)
50 federal appellate · 1 district · 4 state decisions
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 18 U.S.C. § 1792 · 18 U.S.C. § 2 · 18 U.S.C. § 2113 · 18 U.S.C. § 659
Relies on Berger v. United States · Pereira v. United States · Stirone v. United States · Nye & Nissen v. United States · Bain Jr
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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The problem is not so much that the acquittal of the so-called principal requires the acquittal of the aider and abettor. Under statutes such as 18 U.S.C. § 2, the aider and abettor is in law guilty of the substantive offense to the same extent as the so-called principal. The offense of each is complete in itself without the dependency of one on the other. . . . The grand jury did not indict Bryan as a principal. It did not indict him as an aider and abettor of persons unknown. It indicted him as an aider and abettor of a specific named principal. The Government in response to a motion for a bill of particulars reiterated that Echols was the thief who stole the whiskey with an intent to convert it to his own use and that Bryan aided and abetted Echols by supplying the means by which Echols converted the whiskey to Echols' own use. . . . The district court may not convict him of being an aider and abettor on the basis of evidence relevant only to a charge of being a principal; a charge for which he was not indicted.”
1 later decision quote this exact passage · from the dissent“Now, after the case is closed, and after Bryan has lost the opportunity to testify in his own behalf, the majority sustains the conviction on a theory that the grand jury did not consider, that the Government’s case did not present, and of which neither before nor during the trial was Bryan given notice.”
1 later decision quote this exact passage · from the dissent“Administration of a technical and often semantical criminal justice system is the price we pay for the balance struck in the Constitution between the federal government and the individual defendant.”
1 later decision quote this exact passage · from the dissent
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.