Commonwealth v. Sattazahn’s Empirical Analysis

Citation profile

68 state decisions

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 70 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Strategic choices made following less than complete investigation are reasonable precisely to the extent that reasonable professional judgment supports the limitation of the investigation. In undertaking the necessary assessment, reviewing courts are to take all reasonable efforts to avoid the distorting effects of hindsight. Nevertheless, courts must also avoid post hoc rationalization of counsel’s conduct.”

   3 later decisions quote this exact passage
   e.g. Miller v. Beard · Commonwealth v. Miller

2. “To the degree that [appellant's] claims failed on merit or arguable merit, there is no basis for an accumulation claim. To the extent that individual dispositions have centered on the absence of sufficient prejudice to give rise to relief on an individual basis, we are also satisfied that prejudice would be lacking on a collective basis relative to those claims as well.”

   2 later decisions quote this exact passage · from the concurrence
   e.g. In the Interest of R.D. · In Re RD

3. “[l]t is difficult to disagree with [the appellant] that a defense which amasses only four pages of transcript simply does not reflect adequate preparation or development of mitigating evidence by counsel representing a capital defendant in a penalty phase hearing.”

   1 later decision quote this exact passage
   e.g. Commonwealth v. Birdsong