United States v. Lang’s Empirical Analysis
589 F.2d 92 · 1978
Citation profile
55 federal appellate · 13 state decisions
How this case has been cited
Cited by 86 later decisions — most recently November 2023 · most notably United States v. Ammar (1983), United States v. Wuagneux (1982)
55 federal appellate · 13 state decisions — followed in 10 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
Applies 18 U.S.C. § 472
Relies on Wong Sun v. United States · Ohio Bureau of Employment Services v. Hodory · Dutton v. Evans · Krulewitch v. United States · Barrett v. United States
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 86 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Rule does not require that the declarant be aware that the incriminating statement subjects him to immediate criminal prosecution. Rather, it simply requires that the incriminating statement sufficiently “tended” to subject the declarant to criminal liability “so that a reasonable man in his position would not have made the statement unless he believed it to be true.””
4 later decisions quote this exact passage · from the majority“(b) Hearsay Exceptions. The following are not excluded by the hearsay rule if the declarant is unavailable as a witness: (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.[ 7 ]”
2 later decisions quote this exact passage · from the majority“[T]he law appears to be well settled that the power of the Executive Branch to grant immunity to a witness is discretionary....”
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.