Edwards v. United States’s Empirical Analysis
564 F.2d 652 · 1977
Citation profile
31 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 55 later decisions (2 by the Supreme Court) — most recently April 2009 · most notably Christian v. United States (1978), Metheny v. Mc Hamby (1988)
31 federal appellate · 3 district · 1 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. § 2113 · 18 U.S.C. § 2518 (Electronic Communications Privacy Act of 1986) · 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Stone v. Powell · Hill v. United States · Davis v. United States · Difronzo v. United States · Blitz v. Boog
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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the absurd conclusion that any non-harmless error in a federal criminal trial would provide grounds for collateral attack.”
2 later decisions quote this exact passage · from the majority“the Solicitor General contends that we should affirm the judgment of the Court of Appeals because the petitioner’s claim is not “of constitutional dimension” (Brief for United States 34) and thus is not cognizable in a § 2255 collateral proceeding. At the outset, we note that the Government’s position finds scant support in the text of § 2255, which permits a federal prisoner to assert a claim that his confinement is “in violation of the Constitution or laws of the United States.” (Emphasis added.) It is argued forcefully in a dissenting opinion today that this language, which appears in the first paragraph of § 2255, is somehow qualified by the third paragraph of the statute, which provides: “If the court finds that the judgment was rendered without jurisdiction, or that the sentence imposed was not authorized by law or otherwise open to collateral attack, or that there has been such a denial or infringement of the constitutional rights of the prisoner as to render the judgment vulnerable to collateral attack, the court shall vacate and set the judgment side and shall discharge the prisoner or resentence him or grant a new trial or correct the sentence as may appear appropriate.” The dissent of Mr. Justice REHNQUIST rejects any suggestion that the language concerning “sentence[s] . . . otherwise open to collateral attack” can encompass a claim that a confinement under that sentence violates the “laws of the United States,” contending that this would reduce the remaining lang”
1 later decision quote this exact passage · from the majority“a fundamental defect which inherently results in a complete miscarriage of justice ... present[ing] exceptional circumstances where the need for the remedy afforded by habeas corpus is apparent.”
1 later decision quote this exact passage · from the majoritye.g. Reilly v. Warden
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.