Winfield v. United States’s Empirical Analysis
1994
Citation profile
7 state decisions
How this case has been cited
Cited by 7 later decisions — most recently June 2020
7 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 Chambers v. Mississippi · Johnson v. United States · Michigan v. Clifford · Johnson v. United States · Benjamin v. Brown
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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Before evidence that there is a reasonable probability that someone else committed the charged offense can be deemed relevant, and thereby admissible, the evidence must “clearly link” the other person to the commission of the crime.... What we mean by “clearly link” ... is proof of facts or circumstances which tend to indicate some reasonable possibility that a person other that the defendant committed the charged offense. This proof permits the admission of evidence which otherwise is generally excluded because it is too remote in time and place, completely unrelated or irrelevant to the offense charged, or too speculative with respect to the third party’s guilt.”
2 later decisions quote this exact passage“Well, Winfield as it appears in 652 Atlantic Reporter 2nd series ... stand[s] for the proposition that before the defendant may present evidence that someone else may have committed the crime, there must be evidence clearly linking that other person or persons to the facts of the crime on trial. The fact that motive of others alone is not sufficient to meet the foundation for the admission. There must be a nexus between the evidence concerning some other possible person and the crime charged.... ... [I]t is not surprising that during the course of a person’s lifetime there may be other enemies, other than the defendant. The evidence, which the Court thus far is aware is that some people linked Mr. Resper’s car to the scene and Mr. Res-per to the scene. Other than Mr. Eli Alexander there seems no clear linking of anyone else. And so the Court will preclude the presentation of evidence that others had a motive.”
1 later decision quote this exact passage“The inherent ambiguity of this evidence supposedly linking Mr. Huff to the murder would not ... tend to create a reasonable doubt that the defendant who was apparently known by many of the eyewitnesses did not [sic ] commit the offense. Furthermore, given the quality of the evidence proffered and even assuming its relevance, its probity ... in clearly linking Mr. Huff to the murder is so weak and the resulting potential of the evidence to confuse and mislead the jury so great that the Court concludes that on the state of the present record the defense should be precluded from presenting any evidence to show that Mr. Huff may have killed the decedent_ [Emphasis added].”
1 later decision 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.