Carella v. California’s Empirical Analysis
1989
Citation profile
468 federal appellate · 12 district · 443 state decisions
How this case has been cited
Cited by 1,135 later decisions (39 by the Supreme Court) — most recently December 2024 · most notably Arizona v. Fulminante (1991), Estelle v. McGuire (1991)
468 federal appellate · 12 district · 443 state decisions — followed in 35 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 Chapman v. State of California · In the Matter of Samuel Winship · Morissette v. United States · Sandstrom v. Montana · Duncan v. State of Louisiana
Cited together with Rose v. Clark · Chapman v. State of California · Sullivan v. Louisiana · In the Matter of Samuel Winship · Arizona v. Fulminante
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 1,135 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“When the predicate facts relied upon in the instruction, or other facts necessarily found by the jury, are so closely related to the ultimate fact to be presumed that no rational jury could find those facts without also finding that ultimate fact, making those findings is functionally equivalent to finding the element required to be presumed.”
18 later decisions quote this exact passage · from the concurrence“directly foreclosed independent jury consideration of whether the facts proved established certain elements of the offenses with which Carella was charged.”
10 later decisions quote this exact passage · from the majority““In many cases, the predicate facts conclusively establish intent, so that no rational jury could find the defendant committed the relevant criminal act but did not intend to cause the injury .... In that event the erroneous instruction is simply superfluous: the jury has found, in Winship’s words, ‘every fact necessary’ to establish every element of the offense beyond a reasonable doubt.””
9 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.