United States v. McLeod’s Empirical Analysis
53 F.3d 322 · 1995
Citation profile
26 federal appellate · 2 district · 39 state decisions
How this case has been cited
Cited by 76 later decisions — most recently February 2026 · most notably United States v. Goldberg (1995), United States v. Veal (1998)
26 federal appellate · 2 district · 39 state decisions — followed in 20 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
Applies 18 U.S.C. § 1513 · 18 U.S.C. § 1515 · 18 U.S.C. § 3006A (Criminal Justice Act) · 28 U.S.C. § 1491 · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Bonner v. City of Prichard · Illinois v. Allen · Mempa v. Rhay · California State Board of Equalization v. Western Marina Corp. · Patton v. Yount
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 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a defendant who is abusive toward his attorney may forfeit his right to counsel.”
4 later decisions quote this exact passage · from the majority“verbally abusive and threatened to harm him.”
3 later decisions quote this exact passage · from the majority“The Sixth Amendment right to counsel, for example, may be forfeited by a defendant’s failure to retain counsel within a reasonable time, even if this forfeiture causes the defendant to proceed pro se. See Fowler, 605 F.2d at 183. Additionally, a defendant who misbehaves in the courtroom may forfeit his constitutional right to be present at trial. See e.g., Illinois v. Allen, 397 U.S. 337 , 90 S.Ct. 1057 , 25 L.Ed.2d 353 (1970); Foster v. Wainwright, 686 F.2d 1382, 1388-89 (11th Cir.1982), cert. denied 459 U.S. 1213 , 103 S.Ct. 1209, 75 L.Ed.2d 449 (1983). A defendant who causes a witness to be unavailable for trial forfeits his right to confrontation. See United States v. Thevis, 665 F.2d 616, 630 (5th Cir. Unit B 1982), cert. denied, 459 U.S. 825 , 103 S.Ct. 57 , 74 L.Ed.2d 61 (1982). A defendant who escapes from custody during his trial waives his Sixth Amendment rights to be present and to confront witnesses during the trial. See Golden v. Newsome, 755 F.2d 1478, 1481 (11th Cir.1985). By analogy, we conclude that under certain circumstances, a defendant who is abusive toward his attorney may forfeit his right to counsel.”
1 later decision quote this exact passage · from the majoritye.g. State v. Thompson
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.