United States v. Cala’s Empirical Analysis
521 F.2d 605 · 1975
Citation profile
42 federal appellate · 15 state decisions
How this case has been cited
Cited by 67 later decisions — most recently November 2018 · most notably United States v. Guillette (1976), Fed. Sec. L. Rep. P 96,308, 2 Fed. R. Evid. Serv. 1257 United States of America v. David Stirling, Jr., William G. Stirling, Harold M. Yanowitch, Edwin J. Schulz and Rubel L. Phillips (1978)
42 federal appellate · 15 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. § 371 · 18 U.S.C. § 472 · 18 U.S.C. § 473
Relies on Ashe v. Swenson · Patterson v. United States · Sealfon v. United States · Yi Au Lau v. United States Immigration & Naturalization Service · Acosta v. United States
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 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In determining what issues were necessarily resolved by the prior proceedings, the court is to take a practical approach, examining the record, pleadings, evidence and jury instructions in order to decide “whether a rational jury could have grounded its verdict upon an issue other than that which the defendant seeks to foreclose from consideration.” Ashe v. Swenson, supra, 397 U.S. at 444 , 90 S.Ct. at 1194 ; Sealfon v. United States, 332 U.S. 575 , 579, 68 S.Ct. 237 , 92 L.Ed. 180 (1948); United States v. Tramunti, supra, 500 F.2d at 1346 . If the jury could have done so in the prior case, the claim of collateral estoppel must fail, since the defendant can prevail only if the issue which he seeks to preclude from consideration was “necessarily” resolved in his favor in the prior proceeding.”
3 later decisions quote this exact passage · from the majority“The burden . . . is on [the one asserting collateral estoppel] to establish that the issue he seeks to foreclose from litigation in the present prosecution was necessarily decided in his favor by the prior verdict.”
3 later decisions quote this exact passage · from the majority“necessarily determined in favor of the defendant by a valid and final judgment in a prior proceeding.”
2 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.