Harmelin v. Michigan’s Empirical Analysis
1991
Citation profile
1,195 federal appellate · 122 district · 2,055 state decisions
How this case has been cited
Cited by 4,847 later decisions (58 by the Supreme Court) — most recently December 2025 · most notably Atkins v. Virginia (2002), Lockyer Attorney General of California v. Andrade (2003)
1,195 federal appellate · 122 district · 2,055 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.
Relationships
Relies on Carroll v. United States · Florida v. Royer · United States v. Mendenhall · Gregg v. Georgia · Furman v. Georgia
Cited together with Solem v. Helm · Rummel v. Estelle · Ewing v. California · Hutto v. Davis · Lockyer Attorney General of California v. Andrade
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 4,847 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“extreme sentences that are 'grossly disproportionate' to the crime.”
268 later decisions quote this exact passage · from the dissent“(i) the gravity of the offense and the harshness of the penalty; (ii) the sentences imposed on other criminals in the same jurisdiction; and (iii) the sentences imposed for commission of the same crime in other jurisdictions.”
39 later decisions quote this exact passage · from the dissent“intra- and inter-jurisdictional analyses are appropriate only in the rare case in which a threshold comparison of the crime committed and the sentence imposed leads to an inference of gross disproportionality.”
20 later decisions 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.