United States v. Elbert’s Empirical Analysis
561 F.3d 771 · 2009
Citation profile
23 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 46 later decisions — most recently May 2025 · most notably United States v. Yarrington (2011), United States v. Jungers (2013)
23 federal appellate · 1 district · 2 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. § 1591 (§ 112 of the Trafficking Victims Protection Act of 2000)
Relies on United States v. Scheffer · Michigan v. Lucas · United States v. Bartlett · Guarro v. United States · United States v. Ballew
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Because the victim[] [was a] minor[] and could not legally consent; the- government did not need-to prove the elements of fraud, force, or coercion, which are required for adult victims. Instead, .the government, was only required to prove [Gemma] knowingly recruited, enticed, harbored, -transported, provided, or obtained a minor, knowing the minor would be caused to engage in commercial sex acts. -”
5 later decisions quote this exact passage · from the majority“The purpose of an offer of proof is to inform the court and opposing counsel of the substance of the excluded evidence and to provide the appellate court with a record sufficient to allow it to determine if the exclusion was erroneous.”
2 later decisions quote this exact passage · from the majority“need not definitively decide the sufficiency of [Walker's] offer of proof because, regardless of the standard of review, [Walker's] claim fails.”
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.