Cone v. Bell’s Empirical Analysis
2009
Citation profile
374 federal appellate · 61 district · 171 state decisions
How this case has been cited
Cited by 999 later decisions (14 by the Supreme Court) — most recently March 2026 · most notably Connick v. Thompson (2011), 176 L. Ed. 2d 678 - Renico v. Lett (2010)
374 federal appellate · 61 district · 171 state decisions — followed in 28 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
reviewedCone v. Bell (from Sixth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Strickland v. Washington · Brady v. State of Maryland · United States v. Bagley · Coleman v. Thompson · United States v. Agurs
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 999 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“evidence is 'material' within the meaning of Brady when there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different.”
15 later decisions quote this exact passage · from the majority“With respect to evidence and witnesses, the prosecutor has responsibilities different from those of a lawyer in private practice: the prosecutor should make timely disclosure to the defense of available evidence, known to him, that tends to negate the guilt of the accused, mitigate the degree of the offense, or reduce the punishment. Further, a prosecutor should not intentionally avoid pursuit of evidence merely because he believes it will damage the prosecution’s case or aid the accused.”
8 later decisions quote this exact passage · from the dissent“[w]hen a state court declines to review the merits of a petitioner’s claim- on the ground that it has done so already, it creates no bar to federal habeas review. ... When a state court refuses to readjudicate a claim on the ground that it has been previously determined, the court’s decision does not indicate that the claim has been procedurally defaulted. To the contrary, it provides strong evidence that the claim has already been given full consideration by the state courts and thus is ripe for federal adjudication. A claim is procedurally barred when it has not been fairly presented to the state courts for their initial consideration — not when the claim has been presented more than once.”
7 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.