Commonwealth v. Grant’s Empirical Analysis
2002
Citation profile
24 federal appellate · 638 state decisions
How this case has been cited
Cited by 700 later decisions (2 by the Supreme Court) — most recently November 2025 · most notably Massaro v. United States (2003), Commonwealth v. Freeman (2003)
24 federal appellate · 638 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 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Anders v. California · Brady v. State of Maryland · United States v. Cronic · Chevron Oil Co. v. Huson · Jones v. Barnes
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 700 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“as a general rule, a petitioner should wait to raise claims of ineffective assistance of trial counsel until collateral review.”
16 later decisions quote this exact passage“Waiting to raise claims on collateral review affords the opportunity to develop a factual basis for the claim that counsel’s performance did not meet the standard for effective assistance of trial counsel. Many of these claims are based on omissions, which, by their very nature, do not appear on the record and thus, require further fact-finding, extra-record investigation and where necessary, an evidentiary hearing. Related to this rationale is the general belief that an appellate court should not consider issues that were not raised and developed in the court below. Courts have recognized that this general rule and its accompanying rationale apply equally to ineffectiveness claims.”
4 later decisions quote this exact passage“determined more accurately after the trial and appellate courts have had the opportunity to review the alleged claims of error and if necessary, correct any trial court errors. It is only after this review that the full effect of [the after-discovered evidence] can be placed in the context of the case.”
4 later decisions quote this exact passage
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.