Lockhart v. Fretwell’s Empirical Analysis
1993
Citation profile
1,303 federal appellate · 197 district · 1,954 state decisions
How this case has been cited
Cited by 5,073 later decisions (26 by the Supreme Court) — most recently March 2026 · most notably Williams v. Taylor (2000), Arizonans for Official English v. Arizona (1997)
1,303 federal appellate · 197 district · 1,954 state decisions — followed in 40 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 Eighth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Strickland v. Washington · Miranda v. State of Arizona Vignera · Glasser v. United States · United States v. Wade · Stovall v. Denno
Cited together with Strickland v. Washington · Williams v. Taylor · Teague v. Lane · Lindh v. Murphy · Brecht v. Abrahamson
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 5,073 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“that counsel's errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.”
149 later decisions quote this exact passage · from the majority“there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different.”
98 later decisions quote this exact passage · from the concurrence“whether counsel's deficient performance renders the result of the trial unreliable or the proceeding fundamentally unfair.”
46 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.