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← 591 F.2d 513 - United States v. Eubanks

United States v. Eubanks’s Empirical Analysis

591 F.2d 513 · 1979

Citation profile

232
cited by 232 later decisions
15
states following
June 2022
most recently cited

172 federal appellate · 3 district · 22 state decisions

How this case has been cited

Cited by 232 later decisions — most recently June 2022 · most notably United States v. Whitten (1983), United States v. Tarantino (1988)

172 federal appellate · 3 district · 22 state decisions — followed in 15 states

1060197919801990200020102020decided

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 Bruton v. United States · Kotteakos v. United States · Irvin v. Dowd · Dutton v. Evans · Krulewitch 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 232 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “even if 'only one juror is unduly biased or prejudiced,' the defendant is denied his constitutional right to an impartial jury”
    4 later decisions quote this exact passage · from the majority
  2. “[i]f it is possible under the evidence for the jury to find that multiple conspiracies existed, then the court should instruct the jury on the issue.”
    2 later decisions quote this exact passage · from the majority
  3. “In contrast, most of the statements made by Gonzales to Baca that incriminated appellants cannot reasonably be considered to have been in furtherance of the conspiracy. Gonzales and Baca had been living together in a common-law marriage relationship. Gonzales often discussed his activities with Baca, who did not participate in the alleged conspiracy until long after its inception. Baca testified that Gonzales told her that he was going to Tucson to obtain narcotics from Yanez. There is no evidence that Gonzales’ statement was a declaration in furtherance of the conspiracy. Gonzales was not seeking to induce Baca to join the conspiracy and his statement did not assist the conspirators in achieving their objective. Gonzales’ “statement was, at best, nothing more than [a] causal admission of culpability to someone he had individually decided to trust.” Similarly, when Gonzales informed Baca about the persons to whom he had spoken over the telephone, he was not making a declaration in furtherance of the conspiracy. Instead, he was merely informing his common-law wife about his activities. . . . After Baca began travelling to Tucson with Gonzales and assisted him with the arrangements for obtaining heroin, she assumed a role in the alleged conspiracy. Yet Baca’s participation in the conspiracy did not convert Gonzales’ statements to her into declarations in furtherance of the conspiracy. Most of Gonzales’ statements to Baca that were included in her testimony did nothing to advanc”
    1 later decision 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.