United States v. Choate’s Empirical Analysis
619 F.2d 21 · 1980
Citation profile
21 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 25 later decisions — most recently July 2009 · most notably United States v. Aguilar (1989), United States v. Wilson (1981)
21 federal appellate · 2 district · 1 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
Relies on Oyler v. Boles · United States v. Caceres · Dalia v. United States · Fitzpatrick v. Bitzer · Sullivan 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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Treasury Department on January 10, 1952, formally abandoned its longstanding “voluntary disclosure policy”. Treasury Department Information Release, No. S-2930; 1955 P-H, par. 18, 604-A. It is, therefore, no longer an administrative basis for declining prosecution in the Revenue Service that a prospective defendant voluntarily revealed his tax fraud to an appropriate official of that Service before any investigation of his affairs had begun. * * * Now the fact that a taxpayer seeks voluntarily to rectify a false return without prodding by investigators or the threat of investigation is given some weight in determining whether to prosecute but is not conclusive of the issue. [U.S. Department of Justice Manual for Criminal Tax Trials, Ch. 1, p. 5.]”
1 later decision quote this exact passage · from the majority“where violation of an agency regulation does not raise a constitutional question and defendant cannot reasonably contend that he relied on the regulation, or that its breach had any effect on his conduct, he may not in a criminal prosecution seek judicial enforcement of the agency regulation by means of the exclusionary rule.”
1 later decision quote this exact passage · from the majoritye.g. United States v. Ani“The fact that not all criminals are prosecuted is no valid defense to the one prosecuted.... [T]he administration of such a matter lies in the discretion of the prosecuting attorney.”
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.