United States v. Valencia’s Empirical Analysis
541 F.2d 618 · 1976
Citation profile
22 federal appellate · 3 district · 4 state decisions
How this case has been cited
Cited by 43 later decisions — most recently September 2015 · most notably United States v. Voigt (1996), Grand Jury Subpoenas Dated December Does Through IV v. United States (1991)
22 federal appellate · 3 district · 4 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 21 U.S.C. § 841 (§ 401 of the Controlled Substances Act)
Relies on Glasser v. United States · Wong Sun v. United States · Escobedo v. Illinois · Alderman v. United States · McNabb 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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We agree with the district court that it was improper for the government to have intruded into an attorney-client relationship by paying an attorney’s secretary for information about his clients. If any convictions here were affected by the taint of this highly irregular, and we trust, unusual arrangement, we would not hesitate to set aside the convictions. However, we believe that no necessary inference of prejudice with respect to appellants can be made on the basis of the government’s intrusion into the privileged relationship between attorney and client. The more recent authority indicates that there must be a showing of prejudice as well as a showing of an intrusion into the privileged relationship. * * * [To make this showing] appellants must demonstrate that specific evidence used in the government’s case against appellants [at trial] was obtained through Miss Reichard [the secretary]. ... The only evidence that should have been used to convict appellants was information that the Government obtained independently of and unrelated to Miss Reichard’s disclosures....”
1 later decision quote this exact passage · from the majority“whichever is appropriate under the circumstances.”
1 later decision 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.