Fry v. Pliler’s Empirical Analysis
2007
Citation profile
517 federal appellate · 68 district · 40 state decisions
How this case has been cited
Cited by 1,213 later decisions (3 by the Supreme Court) — most recently April 2025 · most notably Davis v. Ayala (2015), Small v. Commissioner of Correction (2008)
517 federal appellate · 68 district · 40 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.
Appellate journey
reviewedthe decision below (from Ninth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Brady v. State of Maryland · Chapman v. State of California · Williams v. Taylor · Kotteakos v. United States · Brecht v. Abrahamson
Cited together with Brecht v. Abrahamson · Williams v. Taylor · Chapman v. State of California · Strickland v. Washington · O'NEAL v. McAninch
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 1,213 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]n § 2254 proceedings a court must assess the prejudicial impact of constitutional error in a state-court criminal trial under the “substantial and injurious effect” standard set forth in Brecht v. Abrahamson, 507 U.S. 619 , 113 S.Ct. 1710 , 123 L.Ed.2d 353 (1993), whether or not the state appellate court recognized the error and reviewed it for harmlessness under the “harmless beyond a reasonable doubt” standard set forth in Chapman v. California, 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967).”
13 later decisions quote this exact passage · from the majority“Given our frequent recognition that [the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”)] limited rather than expanded the availability of habeas relief, it is implausible that, without saying so, AEDPA replaced the Brecht standard of actual prejudice with the more liberal AEDPA/Chapman standard which requires only that the state court’s harmless-beyond-a-reasonable-doubt determination be unreasonable. That said, it certainly makes no sense to require -formal application of both tests (AEBPA/Chapman and Brecht) when the latter obviously subsumes the former.”
8 later decisions quote this exact passage · from the majority“[I]f one cannot say, with fair assurance, after pondering all that happened without stripping the erroneous action from the whole, that the judgment was not substantially swayed by the error, it is impossible to conclude that substantial rights were not affected. The inquiry cannot be merely whether there was enough to support the result, apart from the phase affected by the error. It is rather, even so, whether the error itself had substantial influence.”
8 later decisions quote this exact passage · from the majoritye.g. Merolillo v. Yates · Ayala v. Wong
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.