United States v. Thomas’s Empirical Analysis
571 F.2d 285 · 1978
Citation profile
51 federal appellate · 41 state decisions
How this case has been cited
Cited by 106 later decisions (1 by the Supreme Court) — most recently September 2022 · most notably Lee v. Illinois (1986), United States v. Jernigan (2003)
51 federal appellate · 41 state decisions — followed in 15 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.
Relationships
Relies on Joseph Skilken & Co. v. City of Toledo · United States v. Barrett · United States v. Oropeza · United States v. Bagley
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 106 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“read Rule 804(b)(3) to be limited to direct confessions of guilt. Rather, by referring to statements that 'tend' to subject the declarant to criminal liability, the Rule encompasses disserving statements by a declarant that would have probative value in a trial against the declarant.”
6 later decisions quote this exact passage · from the majority“Rule 804(a)(1) requires an express assertion of the privilege and a ruling by the court that the privilege constitutes unavailability [citation omitted], but here the existence of the privilege and [the declarant’s] right to assert it and [the declarant’s] unavailability as a witness are patent. The trial court declared the evidence inadmissible before reaching issues raised by Rule 804. It would be mere formalism to abjure the merits of [the declarant's] claim in these circumstances.”
5 later decisions quote this exact passage · from the majority“(b) Hearsay Exceptions. The following are not included by the hearsay rule if the declarant is unavailable as a witness: [[Image here]] (3) Statement Against Interest. A statement which was at the time of its making so far contrary to the declarant’s pecuniary or proprietary interest, or so far tended to subject him to civil or criminal liability, or to render invalid a claim by him against another, that a reasonable man in his position would not have made the statement unless he believed it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement. [Emphasis added.]”
3 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.